LR 8402

Taxability of Parts Purchased Through an Extended Warranty

June 22, 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 May 14, 2026.

            The facts as presented in your letter ruling request are summarized as follows:

Applicant is a Missouri automobile dealer which also services automobiles. When customers present with a extended warranty, Applicant's standard procedure is to prepare an estimate for the necessary repairs and submit the required information to Company for authorization.  Company has asserted that it is exempt from sales tax and has provided a document identified as a Multi-State Certification. 

ISSUE 1:

            Are sales to Company as a part of the warranty repair process subject to Missouri state and local sales tax?

RESPONSE 1:

            Yes. Applicant's sales to Company of parts relative to the warranty repair process are subject to Missouri state and local sales tax.

            Section 144.020.1, 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."

            There is no indication Applicant's products are sold in anticipation of resale, nor does Company as an entity occupy an exempt status, so the repair parts are subject to tax. The Multi-State Certification form presented is not recognized by the Department of Revenue as a valid exemption certificate.    

            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  If a change occurs, the taxpayer who relies upon an outdated interpretation may be subject to additional taxes, interest, and penalties, which may be imposed prospectively from the date of the change.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 Associate Counsel Kent L. Brown General Counsel's Office, Post Office Box 475, Jefferson City, Missouri 65105-0475, phone (573) 751-0961.

 

Sincerely,

 

Trish Vincent