96-095

Response June 17, 1996

 

 

Request

To: W. Val Oveson

Chairman

 

From: XXXXX

 

Subject: Requesting Declaratory Judgement/Tax Commission Rule R865-1A-5

 

Date: May 22, 1996

 

Dear Mr. Oveson,

 

In the past my company has been coded as a 7699. I’ve spoke with XXXXX, and he directed me to section H, in letter form.

 

I am now manufacturing and doing some sharpening and repair, but more so manufacturing. The requirement to do more manufacturing has called for the purchase of new machinery and some upgrades of the old.

 

Therefore does my company qualify for sales tax exemption on the purchase of these machines?

 

Please feel free to call at any time. Your earliest reply will be awaited.

 

Respectfully,

XXXXX

 

 

June 17, 1996

 

XXXXX

 

Advisory opinion - exemption on manufacturing equipment.

 

Dear XXXXX

 

We have received your request for information pertaining to the sales tax exemption on purchases for manufacturing equipment. As we understand your situation, your operation has been classified in SIC 7699. You have recently shifted your primary business activity from the repair service category to manufacturing parts, tools or bits for use in mining industries. You are in the process of purchasing new machinery or equipment for use in this new operation. We offer the following guidance concerning the sales tax exemption on manufacturing equipment:

 

Sales or leases of machinery and equipment by a manufacturer for use in a new or expanding operations related to the manufacturing process in a Utah manufacturing facility are exempt from sales tax. A manufacturing facility is defined as an establishment described SIC codes 2000 - 3999 of the 1987 Standard Industrial Classification Manual. At the outset,

your operation must fit within a manufacturing SIC code. We understand that you are unsure of your proper SIC classification. From your description, your operation may fall within SIC 3532 (manufacturing of mining machinery and equipment), 3545 (manufacturing machine tool accessories), or some closely related manufacturing code. Assuming that your operation fits within a qualifying manufacturing code, you may purchase manufacturing equipment and machinery tax free under the following conditions:

 

1. The exemption applies only to tangible personal property, not real property or tangible property that is purchased and becomes an improvement to real property. Generally manufacturing equipment remains personal property, but if it is affixed to real property and you have a question about its status, contact us for further information.

 

2. Machinery or equipment must have a useful economic or accounting life of at least three years to be eligible for the exemption.

 

 

3. Machinery or equipment used for an activity that is not part of the manufacturing process, such as equipment used to transport or ship the final product, does not qualify for the exemption. Machinery or equipment that is shared for use in manufacturing and non-manufacturing activities does not qualify for the exemption unless the use in a non-qualifying activity is de minimis. If you are carrying on non-manufacturing activities in addition to manufacturing activities, we caution you about using the same equipment in both operations. Unless the use of the equipment in non-qualifying activities is inconsequential, that use may be enough to disqualify the purchase from the exemption.

 

If you believe that your equipment purchases meet the conditions set out here, you may purchase the equipment tax free. You must complete a sales tax exemption certificate for the vendor’s records. The vendor should have that form on hand.

 

If you have other questions, please contact us.

 

For the Commission,

 

Alice Shearer,

Commissioner