DRS: Ruling 89-247, Personnel Services

 

STATE OF CONNECTICUT
DEPARTMENT OF REVENUE SERVICES

450 Columbus Blvd
Hartford CT 06103
 
 
 
 
 
 

 
 

Ruling 89-247

Personnel Services


Model usage fees are subject to sales tax as an employment service. The agency using models is required to pay the sales tax on the model agency's fee. The advertising agency is the ultimate consumer of the model agency's services. As the ultimate consumer, it must pay the tax on such service and cannot issue a resale certificate.

TIMOTHY F. BANNON
COMMISSIONER

November 29, 1989