Exemptions are the most audited area in California sales tax. Understanding which exemptions apply and documenting them correctly is the difference between a clean audit and a large assessment. This chapter walks through the four main categories.

For sales tax overview, see What is CA Sales Tax?. For resale specifically, see Resale Audits.

If CDTFA is challenging a sales tax exemption you claimed — or you’re unsure which exemptions apply:

California sales tax exemptions are narrow and frequently disputed in audits. A free 15-minute call covers whether the exemptions you applied were correctly documented, what the CDTFA’s examination process looks like, and what your options are if they’re disallowed.

Talk to Sam — Free 15-Minute Call →    Or call: (619) 378-3138

The Four Categories of CA Sales Tax Exemptions

Most CommonResale
Specific PropertyFood / Medicine
Buyer-BasedGovernment / Nonprofit
PartialManufacturing Equip

CA sales tax exemptions.
Category Authority Documentation2
Resale RTC §6091 Form CDTFA-230
Specific Property RTC §6359, §6369, §6374 Category-based
Buyer-Based RTC §6381, §6368 Exemption certificate
Manufacturing Partial RTC §6377.1 CDTFA-230-M certificate

Quick Reference

Jump to category: resale, specific property, buyer-based, or partial manufacturing.

1. Resale Exemption

The most common exemption — purchases for resale are exempt from sales tax under RTC §6091. Requires CDTFA-230 resale certificate from buyer.

If this is you: Wholesaler or retailer selling to resellers. Collect valid CDTFA-230 from each reseller customer. Retain for audit. Resale certificate audits are common.

Resale Certificate Strategy

  1. Obtain CDTFA-230 before making exempt sale.
  2. Verify buyer’s seller’s permit.
  3. Retain certificate for audit period + statute.
  4. Update certificates periodically.
  5. Challenge conversions (resale item used for non-resale).

2. Specific Property Exemptions

California exempts specific categories of property from sales tax. Food for home consumption (RTC §6359), prescription medicine (§6369), certain farming products (§6358), newspapers and periodicals (§6362.5), and others.

If this is you: Your business sells items in exempt categories. No exemption certificate from buyer required — the item itself is exempt. Documentation of the sales by category is required for audit.

3. Buyer-Based Exemptions

Certain buyers are exempt regardless of property: US government (RTC §6381), foreign diplomats, certain nonprofit organizations (§6375 limited).

If this is you: Selling to exempt buyers. Obtain buyer’s exemption certificate. State-government, county-government, and city-government purchases are typically exempt with proper certificates.

4. Partial Manufacturing Exemption (RTC §6377.1)

California offers a 3.9375% partial exemption on manufacturing equipment used in qualified research and development or manufacturing. Reduces the effective rate from 7.25% to 3.3125% on qualified purchases.

If this is you: Manufacturer or R&D company purchasing qualifying equipment. Form CDTFA-230-M certificate. Partial exemption applies to state portion only; district taxes still apply at full rate.

CDTFA auditing exemption claims? Resale certificate audits are common. Book a consultation.

CA Exemption Document Lookup

Exemption documents.
Document Purpose
CDTFA-230 General Resale Certificate
CDTFA-230-M Manufacturing Partial Exemption
CDTFA-230-G Government Exemption
CDTFA-230-D Diplomatic Exemption
RTC §6091 Resale exemption
RTC §6359 Food exemption
RTC §6369 Prescription medicine
RTC §6377.1 Manufacturing partial
CDTFA Publication 103 Sales for Resale

Exemption Statute

  • 3-year CDTFA audit statute.
  • 8-year for substantial understatement.
  • Unlimited for fraud.
  • Certificates must be retained for at least the audit period.

Exemption Audit Patterns

Common exemption audit issues. Source: Brotman Law practice.
Issue Typical Outcome
Missing resale certificates Assessment on exempt claimed sales
Expired certificates Assessment
Invalid buyer seller’s permit Assessment
Converted inventory (resale → own use) Use tax on converted
Manufacturing partial exemption misuse Assessment of partial portion

Exemption Audit Escalation

Examination to Disallowance

CDTFA reviews exemption documentation. Missing or invalid certificates trigger disallowance and assessment.

Assessment to Petition

30-day Petition for Redetermination window.

Appeals Review

CDTFA Appeals, OTA, Superior Court paths.

First 48 Hours of Exemption Audit

  1. Compile all exemption certificates for audit period.
  2. Verify buyer seller’s permits.
  3. Reconcile exempt sales to documented exemptions.
  4. Identify any conversions or misuse.
  5. Engage counsel for material cases.


Brotman Law has represented taxpayers in CDTFA exemption audits across every category. Based in San Diego.

The ROI Question

Exemption audit assessments can be six figures. Professional defense produces documentation and challenges that save multiples of the fee.

When to Engage Attorney

  • Exemption audit notice.
  • Resale certificate dispute.
  • Manufacturing partial exemption audit.
  • Exemption certificate volume issues.

Exemption audit?

15-minute consultation is free.

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