96-123

Response August 23, 1996

 

 

Request

August 8, 1996

 

To XXXXX

 

I would like to request an advisory opinion for the duty free shop at the Salt Lake International Airport.

 

They want to know if sales to Caribbean bound travelers have to pay tobacco tax on cigars.

 

The condition on these sales would be the traveler would have to show his ticket for purchase and then the product would be delivered to the plane.

 

Please respond as soon as possible.

 

XXXXX

 

 

August 23, 1996

 

XXXXX

 

Advisory Opinion - Tobacco tax on tobacco products sold from a duty-free store

 

Dear XXXXX

 

We have received your request for an opinion as to whether the cigarette and tobacco tax is imposed on sales of cigarettes and cigars from the duty-free store at the Salt Lake International Airport. We find as follows:

 

The cigarette and the tobacco taxes are levied on the first sale, purchase, use or storage of cigarettes or tobacco products in this state. See §§59-14-204 and 59-14-302 Utah Code Ann., and Utah Admin. Rule (emphasis added). XXXXX, then is liable for the tax on the products it imports into the state and distributes for sale or resale in Utah. A very narrow exemption exists for products that XXXXX exports directly to dealers outside the state. §59-14-401 Utah Code Ann.

 

You have described a situation in which XXXXX sells cigarettes and tobacco products to the duty-free store for resale. The transaction between XXXXX and the duty-free store is not in international transit, and it is not exempt. The fact that the duty-free shop, in turn, resells the products for movement out of state does not relieve XXXXX from its obligation to pay the tax. Of course, the duty-free store should not be charging additional cigarette or tobacco tax on its sale of these products to consumers.

 

XXXXX must affix stamps to the cigarettes sold to the duty-free store, and it must report and remit the tobacco tax due on sales of other tobacco products to the duty-free store.

 

Please let us know if you have additional questions.

 

For the Commission,

 

Alice Shearer,

Commissioner