SB52: SB52 "Timberlands Recovery, Exemption, and Earnings Stability (TREES) Act"; enact

Georgia law already exempts certain common carriers, such as trucking companies, railroads, airlines, and shipping companies, from paying state sales and use tax on aircraft, watercraft, trains, motor vehicles, and their major parts, as long as those vehicles are used mainly to carry passengers or cargo across state lines. This bill rewrites that exemption in O.C.G.A. § 48-8-3(33) to spell out exactly how the state should decide whether a vehicle qualifies. Under the bill, the test looks at the overall nature of a carrier's interstate business rather than counting miles. The bill specifically says a carrier does not have to prove that most of a vehicle's mileage happens outside Georgia, and the decision cannot rest solely on mileage counts, where terminals or dispatch offices are located, or where maintenance happens. The exemption still does not cover fuel bought or stored in Georgia, which stays taxable. The bill repeals any conflicting laws.

• Rewrites the definition of 'used principally to cross the borders of this state' in Georgia's sales tax exemption law for common carriers (O.C.G.A. § 48-8-3(33)).
• Directs tax officials to judge eligibility by a carrier's overall interstate business pattern rather than a strict mileage count.
• Bars the state from requiring proof that a majority of a vehicle's miles were driven outside Georgia to qualify for the exemption.
• Prohibits basing the exemption decision solely on mileage, terminal locations, dispatch facilities, maintenance sites, or similar administrative details.
• Keeps in place the existing rule that fuel purchased or stored in Georgia remains subject to state tax even when the vehicle itself is exempt.
• Repeals any other Georgia laws that conflict with this change.

Trucking companies, railroads, airlines, and shipping or barge companies that operate as common or contract carriers across state or international lines, along with Georgia's Department of Revenue, which administers the sales and use tax exemption these businesses rely on.

Carriers that move passengers or cargo across Georgia's borders could have more certainty about qualifying for the tax break on vehicles and vehicle parts, since the state could no longer deny the exemption purely because of how mileage or terminal locations are counted or located.

• Section 1 revises paragraph (33) of O.C.G.A. § 48-8-3 to redefine 'used principally to cross the borders of this state' for aircraft, watercraft, rail equipment, and motor vehicles owned by common carriers.
• The new definition bases eligibility on the overall nature of a carrier's interstate operations, not strict mileage percentages.
• The bill lists factors that alone cannot determine eligibility: mileage, terminal location, dispatch facilities, maintenance operations, or similar administrative factors.
• The exemption continues to exclude fuel bought and delivered in Georgia or fuel bought elsewhere and stored in Georgia, which remains taxable.
• Section 2 repeals any conflicting laws.

1. 2026-04-02House Passed/Adopted By Substitute (House)
2. 2026-04-02House Third Readers (House)
3. 2026-03-31House Committee Favorably Reported By Substitute (House)
4. 2025-02-20House Second Readers (House)
5. 2025-02-19House First Readers (House)
6. 2025-02-18Senate Passed/Adopted By Substitute (Senate)
7. 2025-02-18Senate Third Read (Senate)
8. 2025-02-18Senate Engrossed (Senate)

• Russ Goodman (R, SD-008)Primary sponsor
• John Kennedy (R, SD-018)
• Blake Tillery (R, SD-019)
• Steve Gooch (R, SD-051)
• Harold Jones (D, SD-022)
• Freddie Sims (D, SD-012)
• Kim Jackson (D, SD-041)
• Jason Anavitarte (R, SD-031)
• Billy Hickman (R, SD-004)
• Bill Cowsert (R, SD-046)
• Sam Watson (R, SD-011)
• Drew Echols (R, SD-049)
• Max Burns (R, SD-023)
• Matt Brass (R, SD-006)
• Chuck Payne (R, SD-054)
• Carden Summers (R, SD-013)
• Lee Anderson (R, SD-024)
• Jason Esteves (D, SD-035)
• Michael Rhett (D, SD-033)
• Ricky Williams (R, SD-025)
• RaShaun Kemp (D, SD-038)
• Ed Setzler (R, SD-037)
• Sally Harrell (D, SD-040)
• David Lucas (D, SD-026)
• Josh McLaurin (D, SD-014)
• Ben Watson (R, SD-001)
• Nikki Merritt (D, SD-009)
• Elena Parent (D, SD-044)
• Tonya Anderson (D, SD-043)
• Gail Davenport (D, SD-017)
• Kenya Wicks (D, SD-034)
• Clint Dixon (R, SD-045)
• Ed Harbison (D, SD-015)
• Sheikh Rahman (D, SD-005)
• Nabilah Islam Parkes (D, SD-007)
• Sonya Halpern (D, SD-039)
• Bruce Williamson (R, HD-112)

1. PassedSenate voteFebruary 18, 2025

   31 yea, 20 nay (2 not voting, 3 absent)

   Motion To Engross: Senate Vote #57

2. PassedSenate voteFebruary 18, 2025

   53 yea, 0 nay (0 not voting, 3 absent)

   Passage By Substitute: Senate Vote #58

3. PassedHouse voteApril 2, 2026

   172 yea, 2 nay (1 not voting, 1 absent)

   Passage: House Vote #872

• sales tax exemptions
• trucking and freight
• interstate commerce
• Georgia tax law