SAP America, Inc. v. David Gerregano, Commissioner of Revenue, State of Tennessee

CourtCourt of Appeals of Tennessee
DecidedMay 13, 2026
DocketM2024-01399-COA-R3-CV
StatusPublished
AuthorJudge Andy D. Bennett

This text of SAP America, Inc. v. David Gerregano, Commissioner of Revenue, State of Tennessee (SAP America, Inc. v. David Gerregano, Commissioner of Revenue, State of Tennessee) is published on Counsel Stack Legal Research, covering Court of Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SAP America, Inc. v. David Gerregano, Commissioner of Revenue, State of Tennessee, (Tenn. Ct. App. 2026).

Opinion

05/13/2026 IN THE COURT OF APPEALS OF TENNESSEE AT NASHVILLE August 6, 2025 Session

SAP AMERICA, INC. V. DAVID GERREGANO, COMMISSIONER OF REVENUE, STATE OF TENNESSEE

Appeal from the Chancery Court for Davidson County No. 20-1249-II Anne C. Martin, Chancellor

No. M2024-01399-COA-R3-CV

The Tennessee Department of Revenue issued a business tax assessment against a company based on the company’s gross receipts from sales of computer software, cloud hosting, and cloud-based services. The company challenged the assessment by filing a complaint in the chancery court. Both parties filed motions for summary judgment. The court granted summary judgment to the company, finding that the sales of computer software and cloud hosting were not subject to business tax. The court upheld the Tennessee Department of Revenue’s assessment of business tax against the company’s sales of cloud-based services. Lastly, the court found that the company was the prevailing party and awarded the company attorney’s fees pursuant to Tenn. Code Ann. § 67-1-1803(d). The Tennessee Department of Revenue appealed. Discerning that the court erred in its determination that the company’s cloud hosting sales were not subject to business tax, we reverse that portion of the court’s decision. Because this affects the attorney’s fees award, we vacate the award of attorney’s fees and remand for further proceedings. We affirm the trial court in all other respects.

Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Chancery Court Affirmed in Part, Reversed in Part, Vacated in Part, and Remanded

ANDY D. BENNETT, J., delivered the opinion of the Court, in which J. STEVEN STAFFORD, P.J., W.S., and JEFFREY USMAN, J., joined.

Jonathan Skrmetti, Attorney General and Reporter, J. Matthew Rice, Solicitor General, and Mary Ellen Knack, Senior Assistant Attorney General, for the appellant, Commissioner of Revenue for the State of Tennessee.

Christopher A. Wilson, Michael A. Cottone, and G. Michael Yopp, Nashville, Tennessee, for the appellee, SAP America, Inc. OPINION

FACTUAL AND PROCEDURAL BACKGROUND

This appeal arises from a dispute over a business tax assessment issued for tax years 2014 through 2018. SAP America, Inc. (“SAP”) is a Delaware corporation primarily engaged in the business of selling or licensing enterprise resource planning software (“enterprise software”) developed by SAP or SAP affiliates. SAP’s customers are businesses that use SAP’s enterprise software to perform various tasks associated with managing business operations, including financial functions, human resources, procurement, expense payment, manufacturing, and retail. SAP offers two primary models for customers to purchase licenses to use SAP software: “On-Premise Software” and “Remotely Accessed Software.” Under both models, SAP’s customers purchase the right or license to use SAP’s software. The sole difference between the two models is how SAP’s customers choose to access its software. In other words, On-Premise Software and Remotely Accessed Software are the same product, differing only in how the product is deployed.

Under the On-Premise Software model, a customer purchases a license for a specific enterprise software application from SAP, and SAP provides the customer with a direct download link that allows the customer to download the software from SAP’s servers and install it onto the customer’s own computer or server. The Remotely Accessed Software model is often referred to as “Software as a Service,” “SaaS,” or “cloud computing.” Regardless of the term used, under this model, a customer purchases a license for the right to use the internet to remotely access SAP software located on SAP’s servers. SAP maintains no physical business location in Tennessee, and none of SAP’s servers are located in Tennessee. Thus, none of SAP’s customers download or access software from any servers in Tennessee.

Occasionally, SAP’s customers will request to license software with functionalities that are not included with SAP’s current software offerings. In those instances, SAP sometimes develops software to meet the customer’s needs and then licenses the software to the customer. SAP retains ownership of the software after developing it and will often license the software to other customers seeking the same functionality. This type of software is referred to as Customer-Specific On-Premise Software. For all practical purposes, it is simply a type of On-Premise Software.

For customers that purchase a license to use its On-Premise Software, SAP offers the option to purchase on-going access to software updates, patches, and other fixes that “maintain” the software the customer has licensed from SAP to ensure that it continues performing as expected. The updates and patches consist of computer code and are computer software like the underlying programs to which they correspond. As with the On-

-2- Premise Software, SAP’s customers download the updates, patches, and other fixes from SAP’s out-of-state servers.

If a customer who purchases software from SAP does not want to purchase and maintain its own data center to use the software, the customer may purchase a subscription to access SAP’s Cloud Hosting. SAP’s Cloud Hosting is sometimes referred to as “infrastructure as a service,” “IaaS,” “platform as a service,” or “PaaS.” It allows the customer to access SAP’s servers or hardware infrastructure—none of which are located in Tennessee—so that the customer can deploy, manage, and run the software on SAP’s hardware, or so the customer can gain access to processing, storage, or networking solutions using SAP’s software platform. Under this arrangement, SAP manages the infrastructure accessed by the customer via the cloud.

For customers who elect to remotely access SAP’s software via cloud technology or any other remote manner, SAP provides a variety of services referred to as “Cloud- Based Services.” All of SAP’s Cloud-Based Services are optional and include “Premium Cloud Subscription Support,” “Ancillary Services” for remotely accessed software, “Online Training,” and “Cloud Consulting Services.” The Premium Cloud Subscription Support service provides some SAP customers with optional ongoing software support, such as patches and fixes, and with enhanced account support. With its Ancillary Services offering, SAP provides customers who purchase SAP’s Remotely Accessed Software the option to purchase additional software services such as software configuration. SAP’s Online Training offering allows customers to access training sessions through the internet. Lastly, SAP offers Cloud Consulting Services to its customers. This offering consists of software configuration, data conversion and migration, and related services provided remotely to SAP’s customers.

The Tennessee Department of Revenue (“the Department”) conducted a business tax audit of SAP for the period January 1, 2014, through December 31, 2018. After concluding the audit, the Department issued a Notice of Proposed Assessment on January 31, 2020, imposing business tax on gross receipts derived by SAP from software licensing, Cloud Hosting, and Cloud-Based Services. The total amount of business tax assessed to SAP was $728,080.51, including $485,061 in tax, $121,265.25 in interest, and $121,754.26 in penalty.

In the audit package, the Department determined that SAP was in the “business of selling computer software, cloud services, software consulting services, software programming services, configuration services, and training classes.” The Department classified all of these activities as sales of services under Classification 3 of Tenn. Code Ann. §

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Bluebook (online)
SAP America, Inc. v. David Gerregano, Commissioner of Revenue, State of Tennessee, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sap-america-inc-v-david-gerregano-commissioner-of-revenue-state-of-tennctapp-2026.