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Sales Tax Applies to Payments by Tenants for Leasehold Improvements Unless Certain Conditions are Satisfied

June 9, 2014 Business & Tax Blog Sales Tax

A recent ruling by the Florida Department of Revenue indicates when sales tax will be imposed on leasehold improvements required to be made by a tenant pursuant to a commercial lease. In Technical Assistance Advisement 13A-023, the Department concluded that such leasehold improvements would be considered rent subject to sales tax unless all of the following five conditions are satisfied:

The leasehold improvements are made to put the premises in a condition suitable for the operation of the tenant’s business;

There is no requirement for the tenant to spend a specific or minimum amount of money on the improvements;

There is no credit given against rental payments for the leasehold improvements furnished by the tenant;

The leasehold improvements are not explicitly classified as rent, additional rent, rent-in-kind, or in lieu of rent; and
There is no evidence that the tenant and landlord attempted to reclassify rental payments to avoid tax.

Below is a link to an article that describes the ruling in more detail and addresses related topics.

Sales Tax Applies to Payments by Tenants for Leasehold Improvements Unle… (1)

Michael J. Wilson
mwilson@williamsparker.com
941-536-2043