LTA Sales & Use Tax - Wedding Charges

September 9, 2026

Letter of Technical Advice 

Sales and Use Tax – Wedding Charges 

Sections 212.02, 212.05, 212.055 and 212.17, Florida Statutes (“F.S.”) 

Rule 12A-1.071, Florida Administrative Code (“F.A.C.”) 

BP#: N/A 

Dear Mr. Brennan, 

Pursuant to Rule 12-11.003, F.A.C., taxpayers may seek informal written technical advice from the Department of Revenue. This advice is issued in the form of a Letter of Technical Advice (“LTA”). This LTA is being issued in response to your request for further informal guidance dated July 1, 2026. Please note that this LTA constitutes the opinion of the writer and does not represent the official position of the Department. 

REQUESTED ADVISEMENT 

Whether Florida sales tax or use tax should be charged to Taxpayer’s client under the three scenarios. Specifically, Taxpayer requests confirmation whether 

(i) under Scenario 1, any Florida sales tax should be charged to the client for wedding planning advice only, 

(ii) under Scenario 2, the entire amount Taxpayer charges the client – including Taxpayer’s wedding planning fee – is subject to Florida sales and use tax, notwithstanding that Taxpayer already paid Florida sales tax upon its own purchase or rental of the underlying TPP and third-party services and does not mark up those costs when billed to the client; and 

(iii) under Scenario 3, the entire amount Taxpayer charges the client – including the marked-up cost of the TPP and third-party services and Taxpayer’s wedding planning fee – is subject to Florida sales and use tax

FACTS 

Taxpayer is a wedding and event planner located in Florida. Taxpayer provides wedding planning and coordination services to clients under three different business models, described below as Scenario 1, Scenario 2, and Scenario 3. 

Scenario 1: In the first fact pattern, Taxpayer charges the bride and/or groom a fee solely for wedding planning and consulting services. Taxpayer advises the client regarding vendor selection, timeline creation, design concepts, and overall event coordination. The client, however, contracts directly with, and pays directly, all third-party vendors, including caterers, table and chair rental companies, florists, and the venue. Taxpayer does not purchase, lease, invoice for, mark up, or otherwise resell any tangible personal property (“TPP”) or third-party services to the client in connection with Scenario 1. Taxpayer’s sole compensation under Scenario 1 is the flat or hourly planning fee paid by the client for Taxpayer’s advisory and coordination services. No sales tax is charged to the client. 

Scenario 2: In the second fact pattern, Taxpayer itself contracts with, and pays, all third-party vendors, including caterers, table and chair rental companies, florists, and the venue. Taxpayer also purchases or rents all TPP used at the event. Taxpayer pays Florida sales tax on its own purchases and rentals of such TPP and third-party services at the time of acquisition. Taxpayer then bills the bride and/or groom (i) the exact cost of the TPP and third-party services procured, without any markup, and (ii) a separately stated wedding planning fee. Under Scenario 2, Taxpayer is the party that purchases, rents, and passes through the TPP and third-party services to the client, and the client has no direct contractual relationship with the underlying vendors. No sales tax is charged to the client. 

Scenario 3: The third fact pattern is identical to Scenario 2, except that Taxpayer does not pay Florida sales tax when it purchases or rents the TPP and third-party services used at the event. Instead, because Taxpayer intends to resell such TPP and third-party services to the client, Taxpayer purchases and rents the same tax-exempt for resale by extending a Florida Annual Resale Certificate for Sales Tax (Form DR-13) to its suppliers and vendors. As in Scenario 2, Taxpayer itself contracts with and pays all third-party vendors and purchases or rents all TPP used at the event. Taxpayer then bills the bride and/or groom a marked-up price for the TPP and thirdparty services procured, in addition to a separately stated wedding planning fee. Taxpayer charges a separately stated amount for Florida sales tax on the entire invoice amount relating to TPP, third party services, and wedding planning fee. 

LAW AND DISCUSSION 

Unless specifically exempt, s. 212.05, F.S., provides that “every person is exercising a taxable privilege who engages in the business of selling or leasing tangible personal property¹ in this state.” Section 212.02(15)(a), F.S., provides that a “sale” of tangible personal property includes the license, lease, or rental of tangible personal property. Pure service transactions that do not involve the sale or rental of tangible personal property are generally not subject to tax under Florida law, unless the taxation of the service is specifically authorized by Chapter 212, F.S. Sales tax applies to the “sales price,” and includes “the total amount paid for tangible personal property, including any services that are a part of the sale.” See s. 212.02(16), F.S. Therefore, when tangible personal property and services are sold or rented as part of the same transaction, the entire price charged to the customer is subject to tax. 

Rule 12A-1.039, F.A.C, provides guidance regarding sales for resale under Chapter 212, F.S., and provides that the exemption applies only to sales in strict compliance with the Rule. A sale for resale is exempt from tax when the sale is of tangible personal property sold to an active registered dealer when such property will be resold to the dealer's customers, and the purchasing dealer issues the selling dealer a valid Annual Resale Certificate (DR-13). 

Section 212.17(1)(b), F.S., provides that a registered dealer that purchases property for the dealer’s own use, pays tax on acquisition, and sells the property subsequent to acquisition without having used the property is entitled to reimbursement, in the manner prescribed by the department, of the amount of tax paid on the property’s acquisition. 

CONCLUSIONS 

Scenario 1: Taxpayer’s wedding planning and consulting fees are not subject to Florida sales and use tax to the extent the transactions involve only services and do not include the sale or rental of tangible personal property. 

Scenario 2: Taxpayer’s subsequent sale or rental of tangible personal property to the client is subject to Florida sales and use tax, even if Taxpayer charges the client only its cost and previously paid tax on its acquisition of the property. Any services that are part of the sale are included in the taxable sales price under s. 212.02(16), F.S. Taxpayer may be entitled to reimbursement of tax previously paid on the acquisition of the property if the requirements of s. 212.17(1)(b), F.S., are met. 

Scenario 3: Taxpayer may purchase tangible personal property tax-exempt for resale if the requirements of Rule 12A-1.039, F.A.C., are satisfied. The subsequent sale or rental to the client is taxable, and the taxable sales price includes amounts charged for services that are part of the sale under s. 212.02(16), F.S.

For more information concerning all the taxes administered by the Department of Revenue, please refer to the Department’s Internet site at: www.floridarevenue.com. 

As noted in the first paragraph of this letter, this LTA is being issued in response to the disclosed facts and circumstances of your specific situation and does not constitute the official position of the Department. Rather, this letter represents the opinion of the writer only. If you wish an official binding statement, you may file a written request for a Technical Assistance Advisement. Rule Chapter 12-11, F.A.C., outlines the procedure to follow in making this request. This rule chapter of the Florida Administrative Code can be found at www.flrules.org.

Xiaoxi Miao 

Tax Law Specialist 

Office of Technical Assistance

^{1 Tangible personal property means and includes personal property which may be seen, weighed, measured, or touched or is in any manner perceptible to the senses. See s. 212.02(19), F.S.}