August 5, 1983

__________ Leasing leases trucks. You inquire about the application of the Massachusetts sales tax to your purchase of oil, grease and lubrication for use in rental vehicles.

Massachusetts General Laws Chapter 64H, Section 2 imposes a tax on sales at retail of tangible personal property in the Commonwealth. A lease is a sale for sales tax purposes. (G.L. c. 64H, § 1(12)). Sales of materials which become an ingredient or component part of tangible personal property to be sold are exempt from the sales tax. (G.L. c. 64H, § 6(r)).

Based on the foregoing it is ruled that the purchase of oil, grease and lubrication by __________ solely for use in its lease vehicles is not subject to sales tax. The enclosed exempt use certificate form may be used when making such exempt purchases.

Very truly yours,

/s/Ira A. Jackson

Ira A. Jackson
Commissioner of Revenue

IAJ:MTD:mf

LR 83-71