Summary of Letter Ruling No. 25-8 (Tennessee Dept. of Revenue, 10/24/25):
- True Object of Transaction: The Department determined that the subscription package’s primary purpose is the taxable sale of remotely accessed software, not a health service.
- Role of Software: All tracking, guidance, and health improvement tools are delivered by the mobile app software, not by medical professionals or taxpayer employees.
- Data Generation: Engagement metrics and health outcome reports for clients are generated by the software application itself, reinforcing its classification as a software-based service.
Source Deloitte
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