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Business Taxes Law Guide—Revision 2024

Sales and Use Tax Annotations


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325.0000 Interstate and Foreign Commerce—Regulation 1620

Annotation 325.1510

(c) Shipments from California to Points Outside State

(6) Export Packers and Forwarding Agents

325.1510 Export Packers. Sales to a foreign purchaser, where delivery is made in California to a separate legal entity set up by the foreign purchaser to act as an export packer, will qualify as exempt within section 6387, provided the other requirements of that section are satisfied. To be considered an export packer within section 6387 and Regulation 1620 (a) (3) (C) (1) (b), it is not necessary for a firm to hold itself out to the public as an export packer. It is sufficient if the purchaser and the packer are separate legal entities and the packer is engaged in the business of export packing for the purchaser.

A vendor qualifies as an export packer within section 6387 if the vendor regularly packs and exports, not only goods he has sold to the foreign purchaser, but also goods sold to the foreign purchaser by other vendors. 8/24/72.