Document Number
87-88
Tax Type
Retail Sales and Use Tax
Description
Conversion of computer software
Topic
Taxability of Persons and Transactions
Date Issued
02-27-1987
February 27, 1987




Re: 58.1-1821 Application/Sales and Use Tax


Dear *********************

This will refer to your letter of June 16, 1986, in which you submit an application for correction of sales and use tax assessed to************** and to your recent telephone conversation with a representative of the department's Tax Policy Division.

As noted in your letter, your client is engaged in the "conversion" of computer software, which involves the transfer of information contained on one medium to another medium. The application of the sales and use tax to such transactions was set forth formally in a determination dated January 16, 1986, a copy of which is enclosed. As the operations of the taxpayer in that case are analogous to those of your client, I feel that the enclosed letter will properly answer all of the points raised in your letter with respect to the law and departmental policy applicable to software conversion.

Based upon the policy set forth in my January 16, 1986 determination, the assessment issued to your client must be deemed correct. If you have any questions or concerns regarding this determination, please feel free to contact the department's Tax Policy Division.

Sincerely,


W. H. Forst
Tax Commissioner


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