97-079

Response January 16, 1998

 

 

REQUEST LETTER

 

97-079

 

Dear Irene:

 

Please respond in writing to the following question in writing.

 

FACTS'

 

Company A is located in Colorado and has a Colorado sales and use tax permit. Company A is a

wholesaler of computer hardware and does not have any representation of any kind in your state.

Company A purchases inventory from the manufacturer, Company B, which has a sales and use tax permit in your state. Along with sales of hardware, Company A also purchases services related to the hardware from Company B which are sold to Company C who resells the product and services and collects tax, if applicable, from the final user. Company A, at the direction of

Company C, has the hardware drop-shipped from Company B to the final user in your state.

 

ISSUES:

 

1. Since Company A has no nexus in the state of Utah, they are not required to collect sales tax in your state. Items being purchased by Company A are for resale, but Company A does not have a Utah taxpayer number to include in a resale certificate to give to company B. Can Company A issue a Colorado resale certificate to Company B? If not, what documentation can Company A issue to Company B in order to satisfy them that the sale is for resale?

 

2 Can Company A issue a resale certificate to Company B for the purchase of services which is being purchased for resale to Company C?

 

Thank you for your immediate attention in forwarding a response to NAME at the above address. Should you have any questions or need further information, please contact me at XXXXX.

 

Sincerely,

 

NAME

 

 

RESPONSE LETTER

 

January 16, 1998

 

NAME

ADDRESS

CITY STATE ZIP

 

Advisory opinion - documentation for sales tax exemption

 

Dear NAME,

 

We have received your request for information concerning the sales tax exemption documents required when Company A, a wholesaler outside of Utah, purchases inventory and services from Company B, a manufacturer with a Utah sales and use tax permit.

 

As a wholesaler, Company A’s purchase of both the computer hardware and services related to the hardware is exempt from sales tax under Utah Code Ann. §59-12-104(27). However, Utah Administrative Rule R865-19S-29(D) requires all vendors who make wholesale sales to obtain an exemption certificate from the purchaser. We have enclosed an exemption certificate, Form TC-721NR, for your convenience.

 

In response to your first issue, Company A should complete Form TC-721NR and return it to Company B after each purchase from Company B. On the form, Company A should include its Colorado sales and use tax permit number. As to your second issue, the same form can be used to document the purchase of both the hardware and the services purchased.

 

Please let us know if you have other questions.

 

For the Commission,

Joe B. Pacheco,

Commissioner

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