97-015

Response March 10, 1997

 

 

Request

 

February 20, 1997

 

RE: Tax Rate for Salt Lake County and Utah State

 

Joe,

 

Please offer a written response to the following questions:

 

1. Is the current Utah State rate 4.875/%?

 

2 Are there any existing proposals to raise the State rate within the next four years? If so, what is the proposed percentage of increase?

 

3. Prior to 1-1-97, was the combined Salt Lake County and State rate 6.125%?

 

4. Effective 1/1/97, was the combined Salt Lake County and State rate 6.225%?

 

5. Does the fine State of Utah have a provision in the Sales/Use Tax law/code that, once a construction contract is signed, freezes the State and local option taxes for the duration of the contract? (such as a "Prior Contracts Agreement"?).

 

6. Considering question five above, if a contractor builds a project (improves real property/new construction) and "Maintains" the project for ten years, is there a difference in the contractor’s Sales/Use Tax liability if the contract to improve real property and the maintenance contract are combined or separated?

 

Thanks again, for asking me to review the States new proposed handout.

 

Please advise ASAP.

 

Regards,

 

NAME

 

 

March 10, 1997

 

NAME

ADDRESS

CITY STATE ZIP

 

Advisory Opinion - Sales tax rate applicable to future performance on a contract.

 

Dear NAME,

 

We have received your request for information concerning sales tax rates. We offer the following guidance:

 

1. The current statewide rate in Utah is 4.875 percent. The current combined state and local rate is 5.875 percent, except in areas where a mass transit tax is imposed. The combined state, local and mass transit rate for areas that have imposed the mass transit rate is 6.125 percent.

 

2. Because tax rates are controlled by the legislature and local legislative bodies, we cannot speculate as to tax rate increases over the next four years. For instance, this year the state legislature passed some bills creating new county option taxes. If the governor signs the bills into law, and Salt Lake County acts to impose these additional taxes, the Salt Lake County tax rate will increase.

 

3. Prior to January 1, 1997, the combined rate in Salt Lake County was 6.125 percent.

 

4. Beginning January 1, 1997, the combined rate in Salt Lake County was increased to 6.225. A sales tax rate chart and publication 25 explaining sales and use tax are enclosed for your information.

 

5. Utah does not have a provision to freeze tax rates for the duration of the contract. The applicable sales tax rate is the rate in effect when the sales transaction is completed, not the rate in effect when the contract for sale is signed. A sale is completed when title to the property passes. Utah Administrative Rule R865-19S-31 states, in relevant part:

 

 

Ordinarily, the time and place of a sale are determined by the contract of sale between the seller and buyer. The intent of the parties is the governing factor in determining both time and place of sale subject to the general law of contracts. If the contract of sale requires the seller to deliver or ship goods to a buyer, title to the property passes upon delivery to the place agreed upon unless the contract of sale provides otherwise.

 

Rule R865-19S-31 reflects the statutory test for passage of title set out in the Uniform Commercial Code, Section 70A-2-401 of the Utah Code. Section 70A-2-401 states in part:

 

(1) . . . title to goods passes from the seller to the buyer in any manner and on any conditions explicitly agreed on by the parties.

 

(2) Unless otherwise explicitly agreed title passes to the buyer at the time and place at which the seller completes his performance with reference to the physical delivery of the goods. . . .

 

Because you are considered the final consumer of materials used to construct, repair or maintain real property, the taxable event occurs when you purchase the items. Under the provisions cited above, the purchase takes place when an item is delivered, unless you and your suppliers have contractually agreed otherwise.

 

6. Because your current contract does not freeze the tax rate that will apply to your future transactions, it makes no difference to your tax liability if the maintenance contract is combined with the original contract.

 

As you draft long term contracts with your suppliers and customers, keep two things in mind. First, the time of sale can be controlled to some degree by the terms of your contract. Second, tax rates are always subject to change. You can protect yourself against unforeseen tax rate changes by including provisions for adjustments in your contracts.

 

Thank you for taking time to review our draft publication for real property contractors. The publication should be in print soon.

 

For the Commission,

Joe B. Pacheco,

Commissioner