Letter Rulings
A private taxpayer ruling or a taxpayer information ruling is the department's interpretation of the law or rules only as they apply to the taxpayer making, and the particular facts contained in, the request.
The Department of Revenue (Department) is authorized[1] to issue private taxpayer rulings (PTRs) or taxpayer information rulings (TIRs) to provide Arizona taxpayers with guidance relating to their specific tax situation. A PTR may be requested when the taxpayer’s identity is provided. A TIR may be requested without providing a taxpayer’s identity. When the taxpayer’s identity is known, a PTR may be issued and is binding on the Department. Whereas a TIR is only binding if the taxpayer’s identity is provided to the Department. The identity of the taxpayer does not have to be provided on the initial request for a TIR.
A PTR or TIR is a written statement issued to a taxpayer or the taxpayer representative by the Department’s Tax Policy Section. A PTR or TIR interprets and applies Arizona tax laws to a particular set of facts. The Department will issue a PTR or TIR in response to a written inquiry by a taxpayer, potential taxpayer, or an authorized representative of a taxpayer or potential taxpayer. A taxpayer, potential taxpayer, or an authorized representative may request an informal guidance letter in lieu of a PTR or TIR.
The Department will accept a request for a PTR or TIR in a hard copy (i.e., paper) format. A taxpayer may also send the request through email to [email protected]. The request should be as complete as possible and all relating documentation should be submitted at the time of the request.
Once the Department has received a taxpayer’s request, it will be reviewed and the taxpayer will be contacted within five business days if additional information is needed. The taxpayer should return any requests for additional information from the Department within a minimum of five business days. A letter ruling will be issued within 45 business days after all information (including responses to questions) is received. At any time during the ruling process, the taxpayer may request a conference with the Department by sending an email to [email protected]. The Department may also request a conference with the taxpayer to clarify any outstanding questions or issues.
If a taxpayer or taxpayer representative does not receive a ruling within the timeframe specified above, please reach out to Department employee working on the ruling with a copy to Lisa Querard at [email protected] for more information.
For more information on PTR and TIR requests, please review General Tax Procedure (GTP) 08-1 and General Tax Ruling (GTR) 08-1 on our website.
1 Authorization for letter rulings can be found in the Arizona Revised Statutes (A.R.S.) 42-2101.
Document Type | Category | Document ID | Description | Tags | Decision Date |
---|---|---|---|---|---|
Letter Rulings | Transaction Privilege and Use Taxes | LR17-011 | Taxability of the operator of an online marketplace. |
Prime Contracting, Retail | 07/26/2017 |
Letter Rulings | Transaction Privilege and Use Taxes | LR17-011 | Taxability of the operator of an online marketplace. |
Prime Contracting, Retail | 07/26/2017 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 17-010 | Installation of Solar Power Plant |
Prime Contracting, Retail | 04/28/2017 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 17-010 | Installation of Solar Power Plant |
Prime Contracting, Retail | 04/28/2017 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 17-005 | Propane Delivery and Refill Services |
Retail, Utilities | 01/31/2017 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 17-006 | Propane Delivery and Refill Services | Utilities | 01/31/2017 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 17-005 | Propane Delivery and Refill Services |
Retail, Utilities | 01/31/2017 |
Letter Rulings | Transaction Privilege and Use Taxes | LR17-003 | Prime Contracting v. Service | Prime Contracting | 01/09/2017 |
Letter Rulings | Transaction Privilege and Use Taxes | LR17-002 | Prime Contracting - Dual Entity Structure | Prime Contracting | 01/03/2017 |
Letter Rulings | Transaction Privilege and Use Taxes | LR16-009 | Installation of Solar Components | Prime Contracting | 09/24/2016 |
Letter Rulings | Transaction Privilege and Use Taxes | LR16-011 | Software | Personal Property Rental | 09/23/2016 |
Letter Rulings | Transaction Privilege and Use Taxes | LR16-010 | Governmental vs. Proprietary Function | City Tax | 08/26/2016 |
Letter Rulings | Transaction Privilege and Use Taxes | LR16-008 | Prime Contracting v. service | Prime Contracting | 07/14/2016 |
Letter Rulings | Transaction Privilege and Use Taxes | LR16-007 | Property management TPT liability | City Tax | 07/14/2016 |
Letter Rulings | Transaction Privilege and Use Taxes | LR16-003 | Prime Contracting-dual entity structure | Prime Contracting | 04/18/2016 |
Letter Rulings | Transaction Privilege and Use Taxes | LR16-004 | Prime Contracting-dual entity structure | Prime Contracting | 04/18/2016 |
Letter Rulings | Transaction Privilege and Use Taxes | LR15-006 | Prime Contracting-dual entity structure | Prime Contracting | 06/04/2015 |
Letter Rulings | Transaction Privilege and Use Taxes | LR15-005 | Software | Personal Property Rental | 05/15/2015 |
Letter Rulings | Transaction Privilege and Use Taxes | LR15-001 | Software | Personal Property Rental | 02/24/2015 |
Letter Rulings | Transaction Privilege and Use Taxes | LR15-002 | Taxability of prepackaged food products sold in Arizona and online | Retail | 02/24/2015 |
Letter Rulings | Transaction Privilege and Use Taxes | LR14-001 | Subscription memberships | Personal Property Rental | 04/14/2014 |
Letter Rulings | Transaction Privilege and Use Taxes | LR94-011 | Sublease Allocation | Commercial Lease | 03/28/2014 |
Letter Rulings | Transaction Privilege and Use Taxes | LR13-012 | Mining/processing of nonmetalliferous mineral product | Mining | 11/25/2013 |
Letter Rulings | Transaction Privilege and Use Taxes | LR13-010 | Prosthetic appliance-bone graft | Retail | 07/17/2013 |