Any operator who provides alcohol to a passenger, either at a charge or complimentary, is required by federal law to pay a Special occupations Tax (SOT) of $250 per year as a retail liquor dealer.
The SOT must be paid for each “place” where alcoholic beverages are sold or offered for sale. According to Herschel Stewart, technical advisor for the Federal Bureau of Alcohol, Tobacco and Firearms (BATF). “If there is any fee or charge for obtaining alcohol, the operator must pay the tax for each vehicle where alcohol is being offered. BATF considers that a fee has been paid when the client pays for the limousine service.” In other words, according to the BATF, an operator who offers a complimentary bottle of champagne is “selling” liquor.
Operators can avoid buying a SOT stamp for each vehicle where liquor is available if they offer only complimentary liquor. In this case, an operator would only need to purchase one SOT stamp for the central limousine rental office. “If the client signs a contract that states the consumption of alcohol will have no effect on the price of the service, operators only need to pay the base tax,” adds Stewart.