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Business Taxes Law Guide—Revision 2024

Sales and Use Tax Annotations


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I


325.0000 Interstate and Foreign Commerce—Regulation 1620

Annotation 325.0667

(c) Shipments from California to Points Outside State

(2) Delivery to Purchaser in State


325.0667 Instate Delivery to Purchaser. A printer located in California prints brochures for a customer who is also located in California. The customer notifies the printer that the customer will be shipping half of the brochures to Germany (the brochures are being printed in German). All of the brochures are delivered to the purchaser in California.

Sales tax applies when the property is delivered to the purchaser or the purchaser's representative prior to an irrevocable commitment of the property into the process of exportation. It is immaterial that the disclosed or undisclosed intention of the purchases is to ship or deliver the property to a foreign country or that the property is actually transported to a foreign country. In this case, the brochures are delivered to the purchaser in California. The sale is complete at that time, before the entry of the brochures into the stream of export. Therefore, sales tax applies. 8/8/96.