Tax Type
Retail Sales and Use Tax
Description
Services; Professional or personal; Mapping services
Topic
Taxability of Persons and Transactions
Date Issued
04-20-1994
April 20, 1994
Re: Request for Ruling: Retail Sales & Use Tax
Dear************
This will respond to your letter of August 17, 1993 seeking a ruling on the application of the sales and use tax to mapping services provided by your company (the "Taxpayer") to electric cooperatives and similar customers in Virginia.
The Taxpayer is an out-of-state consulting company that provides services including generating new utility maps and updating existing maps to a Virginia electric cooperative and similar customers. You seek a ruling as to whether the provision of maps is a nontaxable service or the delivery of a taxable product.
As the enclosed copy of Public Document 91-109 (6/28/91) indicates, while a person engaged in the development and sale of maps is providing professional services in the rendition of its operations, the "true object" of the transaction is the end product of the taxpayer's services - the maps themselves. In that case, as in this case, without a suitable finished product, it is not likely the customers would seek the services of the taxpayer. The charges for the updating of a map, likewise, are taxable.
Accordingly, the Taxpayer should include Virginia sales tax on its invoices for maps and map updates to its Virginia customers.
Sincerely,
Danny M. Payne
Acting Tax Commissioner
OTP/7300H
Rulings of the Tax Commissioner