become an ingredient or component part of tangible personal property to be sold or are consumed and used directly and exclusively:.64H, § 6(r), sales of materials, tools and fuels, or any substitute therefor are exempt from sales tax if the materials, tools or fuels: 64H, § 6(r) and § 6(s), as discussed below. Because this test has in some instances proven unwieldy for both taxpayers and the Department of Revenue, DOR is modifying its policy with respect to G.L. 64H, § 6(r) and § 6(s) by demonstrating that they are purchasing certain items as agents for the utilities or other entities who will use the items in the exempt manner specified by the statute. The Department of Revenue has previously allowed contractors and other persons or entities acting for utilities and similar businesses to take advantage of the exemptions provided under G.L.
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