The Missouri Department of Revenue ("Department") recently determined that rentals of intermodal chassis were exempt from sales and use tax. The taxpayer provided intermodal chassis as a marine chassis pool manager. The taxpayer had the intermodal chassis designed to safely haul loaded 20 and 40-foot steel containers with a registered gross vehicle weight rating (GVWR) of at least 80,000 pounds over public roadways. Customers could pick up intermodal chassis for rental on a per diem basis provided they used an authorized motor carrier.
Missouri exempts motor vehicles registered in excess of 54,000 pounds and the trailers pulled by such motor vehicles used in the normal course of business to haul property on the public highways of the state. These trailers must be capable of hauling loads in line with the motor vehicle's registered weight. The Department determined that the intermodal chassis were trailers within the definition of the exemption and were registered to meet the required GVWR threshold. As a result, the intermodal chassis rentals were exempt.