North Carolina Clarifies Subscriptions to Access Software vs. Digital Content
In a November 1, 2024 decision, the North Carolina Department of Revenue determined that a subscription to access digital content is taxable, whereas the same subscription to access nontaxable content is not subject to sales tax. Taxpayer, for a subscription fee, provided users with access to its online learning platform, through which users could access songs, videos, books, printable worksheets, online video games, quizzes and other learning activities. Users could also access online support via a chat feature. Experiences can be adapted to be unique for each user, and the products may be accessed remotely via a web browser or via an application that may be downloaded to a customer’s device. Though North Carolina Code Section 105.164.3(33) imposes sales tax on specified digital products, it does not include information services or educational materials. North Carolina Code Section 105.164.3(253) defines specified digital products to include digital audio works, digital audiovisual works and digital books, under which the Department concluded many of the products on the Taxpayer’s platform fell. In addition, North Carolina does not impose sales tax on Software As a Service.
The Department noted that
While Taxpayer uses software and databases to deliver the content to its customers, the customers are paying for access to the Digital Content and not for the underlying software that is used by Taxpayer to deliver the content. Most, if not all, modern on-demand or streaming digital media content providers use software and databases to deliver content to their customers. The software sorts and allows for searching of the content. The use of such software by the content providers does not allow the providers to avoid tax on their sales of certain digital property. The use of such software by Taxpayer is part of the sales price of certain digital property. Finally, Taxpayer’s products also provide at least one service that would not be subject to sales and use tax as a standalone product. An example would be the math learning software when provided online without the download of prewritten computer software. The standalone sale of this product would be software as a service, a nontaxable service in North Carolina. Since this product is sold for one nonitemized price with the taxable Digital Content, and it appears to meet the other requirements of a bundled transaction, the sale is a bundled transaction.
[SUPLR-2024-0011, North Carolina Department of Revenue (November 1, 2024)]. This decision drives home the point for companies to ensure they understand that it is not simply enough to evaluate your cloud-based on SaaS offerings under the multistate, unamimous determination that if it is Software As a Service, that is how a state will classify it for sales tax purposes. The fact that a subscription to access a software platform is not determinative of its sales tax classification in many states. Companies, and their advisors, must consider what is being accessed, what is being provided to the user, how is it being accessed, how is it being delivered to the user, and how much control over the platform does the user have.