Are UCC fixture filings subject to the indebtedness/mortgage tax imposed pursuant to Tenn. Code Ann. § 67-4-409(b)?

Generally, UCC fixture filings are subject to indebtedness tax.  However, they are not subject to the tax if the incidence of tax is on an entity that is exempt from the tax or if a governmental entity is the mortgagor (lender) or the mortgagee (debtor).  If the filer claims the document is exempt, the proper statute citation must be included on the document.

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