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Are car owners who make their cars available for rental on a P2P (peer-to-peer) platform subject to TPT?

Posted by Brandon Keim | Apr 18, 2025 | 0 Comments

As of 2021, peer-to-peer (P2P) platforms for car sharing are subject to the transaction privilege tax (TPT) in Arizona. The state defines a P2P platform as a business that enables individuals to rent a vehicle. 

P2P platforms, not individuals renting their cars through the platform, are responsible for paying TPT. This is the case as long as an individual's business is not renting cars. 

In other words, if renting a car is a side gig, it's unlikely to require a TPT license. If renting a car is an individual's primary source of income, it may require a TPT license. 

Individuals who rent their vehicles through a P2P platform must certify their vehicle with the Arizona Department of Revenue and show that: 

  • They paid TPT or Arizona's use tax at the time of the vehicle purchase 

or 

  • They paid sales or use tax on a vehicle that was brought into Arizona but was purchased out of state 

What Isn't a P2P Platform 

Arizona explicitly states the following don't follow under the P2P car-sharing platform rules: 

  • Vehicle rentals that include a driver 

  • Rental car agents 

  • Traditional car rental companies, even when a company has a website for renting cars 

The state draws a line between traditional car rental companies and P2 platforms. Car rental companies usually own the vehicles available for rent. In comparison, P2P platforms don't own the cars but are instead a marketplace that allows other people to offer their cars for rent they rent.  

P2P Platforms versus Traditional Car Rentals 

P2P platforms generally involve renting vehicles owned by individuals. Individuals or others who use a P2P platform are usually not in the primary business of renting vehicles. 

In comparison, a rental car company's primary business is renting cars, and cars are purchased primarily to rent. Rental car companies can, however, list cars on a P2P platform. 

When a rental car company lists its cars on a P2P platform, they must report all received gross income on their TPT return. As the P2P platform collects and remits taxes and surcharges, traditional car rental companies may deduct the P2P platform income.  

If you need help, call Senior Partner, Tax Controversy Attorney, and former IRS attorney Brandon A. Keim at (602) 200-7399 or contact him online to discuss your options.

About the Author

Brandon Keim
Brandon Keim

A Certified Tax Law Specialist, CPA, partner at Frazer Ryan Goldberg & Arnold LLP, and former Senior IRS Trial Attorney, Brandon Keim holds an LL.M. in Taxation from Georgetown University Law Center.

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The act of visiting or communicating with Brandon A. Keim via this website or by email does not constitute an attorney-client relationship. Communications from non-clients via this website are not subject to client confidentiality or attorney-client privilege. Further, the articles, discussion, commentary, forms and sample documentation contained in this website are offered as general guidance only and are not to be relied upon as specific legal advice. For legal advice on a specific matter, please consult with an attorney who is knowledgeable and experienced in that area. Attorneys listed in this website practice only in the jurisdictions in which they are admitted. This website is governed by the Arizona Rules of Professional Conduct.

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