Tax Type
Retail Sales and Use Tax
Description
Goods for international clients
Topic
Exemptions
Date Issued
01-03-1986
January 3, 1986
Re: Ruling Request/Exemption Request
Sales Tax
Dear ********************
This will reply to your letter of October 23, 1985, in which you request an exemption from the Virginia Retail Sales and Use Tax for your organization.
FACTS
************* (Organization) is a procurement and shipping company servicing international clients. Organization procures U.S. made goods for its international clients and ships goods to them. Organization takes title to the goods and is named shipper of record.
You request an exemption from the Virginia Retail Sales and Use Tax for the purchase of the U.S. made goods that you export.
RULING
The Virginia Retail Sales and Use Tax is imposed "upon every person who engages in the business of selling at retail or distributing tangible personal property in this State." Virginia Code Section 58.1-602.14 defines "sale at retail" to "mean a sale to any person for any purpose other than for resale."
Based upon the limited information that you have provided, Organization's operations appear to qualify for the resale exemption. To the extent that the first use of the goods is made outside of Virginia and title to the property does not pass to your customer within Virginia, Organization may purchase the goods under a resale exemption certificate (ST-10).
Sincerely,
W. H. Forst
Tax Commissioner
Rulings of the Tax Commissioner