97-073

Response December 8, 1997

 

 

REQUEST LETTER

 

Mr Jeff McNemar,

 

We would like to request an advisory opinion concerning the correct sales tax procedure involving a new lease vehicle. We have just installed a new project from COMPANY A. claims that trade equity used as capitalized reduction of a lease vehicle should be taxed just as if the individual paid in cash. Please provide us with written proof so we can change this setting with COMPANY A. Let me give a couple of examples;

 

Customer A:

 

Cap Cost 25,525.00

Trade Equity Cap Reduction 4,500.00

Sales Tax on Cap Reduction ?????????

 

 

Customer B:

 

Cap Cost 25,525.00

Cash Cap Reduction 4,500.00

Sales Tax on Cap Reduction ?????????

 

Customer C:

 

Cap Cost 25,525.00

Trade Equity Cap Reduction 2,500.00

Cash Cap Reduction 2,000.00

Sales Tax on Cap Reduction ????????

 

We appreciate you assistance in helping us use the correct procedure of state sales tax and your quick response. If you have any questions, please call me at #####.

 

Thank you,

 

NAME

 

RESPONSE LETTER

 

December 8, 1997

 

 

NAME

ADDRESS

CITY STATE ZIP

 

Advisory Opinion - Application of sales tax to trade-in equity on leased vehicles.

 

Dear NAME,

 

Your request for sales tax guidance on vehicle leases has been forwarded to our office . We offer the following advisory opinion in response to your questions pertaining to the application of sales tax on various lease transactions:

 

We begin with the following basic principles: On lease transactions, sales tax is due on the net cost or purchase price of the vehicle. A trade-in reduces the net purchase price only to the extent of the customer’s equity in the trade-in vehicle. Although a cash down payment reduces the amount to be financed, it does not reduce the net purchase price of the leased vehicle or the tax base. With that background, we examine some typical lease transactions:

 

1. The first transaction involves a customer who owns a vehicle and uses that vehicle as a trade-in to reduce the cost of a new vehicle lease. Depending upon the customer’s equity in the trade-in, the transaction may take one of the following forms:

 

a. The customer owns the trade-in outright. The dealer allows $4,500 on the trade-in toward the lease of a $25,500 vehicle.

 

Cap cost of vehicle being leased: $25,500

Trade-in equity value: 4,500

Net cap cost subject to sales tax: 21,000

 

b. The customer still owes $1,500 on the trade-in. The dealer allows $4,500 on the trade-in toward the lease of a $25,500 vehicle.

 

Cap cost of vehicle being leased: $25,500

Trade-in value: $ 4,500

Pay-off amount ( 1,500)

Net equity trade-in value: 3,000 ( 3,000)

Amount subject to sales tax: 22,500

 

2. The second transaction involves a customer who makes a $4,500 down payment to reduce the balance due on a lease transaction. When the customer uses his own cash as a down payment, it only reduces the amount left to be financed. It does not reduce the purchase price upon which sales tax is calculated. The taxable transaction is as follows:

 

Cap cost of vehicle being leased: $25,500

Down payment: $ 4,500

Balance due on lease: 21,000

 

Amount subject to sales tax: 25,500

 

3. The third transaction involves a customer who makes a down payment and also uses a trade-in to reduce the purchase price of the new lease. Depending upon how the customer uses the cash payment, the transaction will take one of the following forms:

 

The customer still owes $1,500 on the trade-in. The dealer allows $5,000 on the trade-in toward the lease of a $25,500 vehicle. In addition, the customer uses $2,000 in cash as a down payment. We assume that $1,500 of the cash down payment will be applied to pay off (or increase equity in) the trade-in. Trade equity and cash down payment used to pay off the trade- in reduces the tax base, but only to the extent of the trade-in value.

 

Cap cost of vehicle being leased: $25,500

Net equity in Trade-in (after payoff): ( 5,000)

Cash down payment (over payoff amt.) $ 500 Balance due on lease: 20,000

Amount subject to sales tax: 20,500

 

Lease transactions can be complex, and we have only addressed the kinds of transactions that were described in your letter. If you have other questions, please contact us again.

 

For the Commission,

Joe B. Pacheco,

Commissioner

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