LR 8392
Taxability of Electronic Textbooks
April 26, 2026
Dear Applicant:
This is a letter ruling issued by the Director of Revenue under Section 536.021.10, RSMo, and Missouri Code of State Regulations 12 CSR 10-1.020, in response to your letter dated March 23, 2026
The facts presented in your letter ruling request are summarized as follows:
Applicant is an institution of post-secondary education in the state of Missouri. Applicant sells textbooks to students as part of their educational activities. Textbooks are sold physically, though some of Applicant's courses require electronic materials that are only accessible through Applicant's learning management system. For these courses, Applicant sells electronic textbooks.
ISSUE:
Should Applicant collect local sales tax on sales of electronic textbooks?
RESPONSE:
No. Applicant should not collect local sales tax on sales of electronic textbooks, as sales of digital property are not taxable under Missouri statute.
Section 144.020.1(1) RSMo, provides: "A tax is hereby levied and imposed...upon all sellers for the privilege of engaging in the business of selling tangible personal property or rendering taxable service at retail in this state."
The purpose statement of 12 CSR 10-110.400 states: "The sale of publications that are not in tangible form is not subject to tax and is not addressed in this rule."
12 CSR 10-110.400 defines publications as "any written material, such as newspapers, magazines, newsletters periodicals, trade journals, and books, offered for sale or distribution."
Applicant offers for sale textbooks, which are written materials. Because the textbooks are delivered electronically and are only accessible through Applicant's learning management system in electronic form, they are not in tangible form. The state of Missouri imposes sales tax only on the transfer of tangible personal property and does not tax sales of computer software unless provided in a tangible medium. Thus, sales of electronic textbooks are not subject to state or local taxes under Missouri statue. Therefore, Applicant should continue their practice of not collecting Missouri state and local sales tax on these sales.
This letter ruling is binding upon the Department of Revenue with respect to the Applicant for three (3) years from the date of this letter and is subject only to statutory changes by the General Assembly and to changes in the interpretation of law by the courts or administrative tribunals. If a change occurs, the taxpayer who relies upon an outdated interpretation may be subject to additional taxes, interest and penalties, which may be imposed prospectively from the date of the change. For this reason, the interpretation set forth above should be reviewed on a regular basis. Please note that any change in or deviation from the facts as presented will render this ruling inapplicable.
Should additional information be needed, please contact Legal Counsel Gabriel Barnes, General Counsel's Office, Post Office Box 475, Jefferson City, Missouri 65105-0475, phone (573) 751-0961.
Sincerely,
Trish Vincent