TITLE 34.PUBLIC FINANCE

Part 1. COMPTROLLER OF PUBLIC ACCOUNTS

Chapter 3. TAX ADMINISTRATION

Subchapter O. STATE SALES AND USE TAX

34 TAC §3.356

The Comptroller of Public Accounts proposes an amendment to §3.356, concerning real property service. The amendment incorporates changes to Tax Code, §151.0048 and §151.347, by prior legislation. The amendment adds definitions for the terms "contractor," "real property services," "residential property," and "self-employed." The change to Tax Code, §151.0048, excludes from the definition of real property services those services purchased by a contractor as part of the construction of new residential structures. The amendment to Tax Code, §151.347, changes the dollar amount for exempt landscaping and lawn maintenance services sold by persons under 18 and explains the limitations that apply to the exemption for self-employed individuals who perform landscaping and lawn maintenance services. As a result of prior legislation, the definition of real property services is amended temporarily from October 1, 1999 to October 1, 2001. During this period, surveying services that were purchased by a homeowner in connection with the construction of a new structure for use as a residence or other improvement of the structure were not taxable services. Amendments to Tax Code, §151.0048, codify and clarify provisions in the section regarding property management companies.

James LeBas, Chief Revenue Estimator, has determined that for the first five-year period the rule will be in effect, there will be no significant revenue impact on the state or units of local government.

Mr. LeBas also has determined that for each year of the first five years the rule is in effect, the public benefit anticipated as a result of enforcing the rule will be in providing additional information concerning tax responsibilities. This rule is adopted under Tax Code, Title 2, and does not require a statement of fiscal implications for small businesses. There is no significant anticipated economic cost to individuals who are required to comply with the proposed rule.

Comments on the proposal may be submitted to Bryant K. Lomax, Manager, Tax Policy Division, P.O. Box 13528, Austin, Texas 78711.

This amendment is proposed under Tax Code, §111.002, which provides the comptroller with the authority to prescribe, adopt, and enforce rules relating to the administration and enforcement of the provisions of Tax Code, Title 2.

The amendment implements Tax Code, §151.0048 and §151.347.

§3.356.Real Property Service.

(a) Definitions. The following words and terms, when used in this section, shall have the following meanings, unless the context clearly indicates otherwise.

(1) Contractor--Any person who builds new improvements to residential or nonresidential real property, completes any part of an uncompleted new structure that is an improvement to residential or nonresidential real property, makes improvements to real property as part of periodic and scheduled maintenance of nonresidential real property, or repairs, restores, maintains, or remodels residential real property, and who, in making the improvement, incorporates tangible personal property into the real property that is improved. The term includes subcontractors but does not include material men, suppliers, or persons who provide taxable real property services. Contractors should refer to §3.291 of this title (relating to Contractors). Persons who repair, restore, or remodel nonresidential real property are providing taxable services and should refer to §3.357 of this title (relating to Nonresidential Real Property Repair, Remodeling, and Restoration; Real Property Maintenance). Persons who repair, restore, or remodel chemical plants or petrochemical refineries should refer to §3.362 of this title (relating to Labor Relating to Increasing Capacity in a Production Unit in a Petrochemical Refinery or Chemical Plant).

(2) Disaster area--

(A) an area that is declared a disaster area by the Governor under Government Code, Chapter 418; or

(B) an area that is declared a disaster area by the President of the United States under 42 U.S.C., §5141.

(3) [ (1) ] Employee--A person who provides [ providing ] services for another for consideration if [ where ] the employer has the right to control and direct the employee in the material details of how the work is to be performed, both under the contract of employment and in fact. The term also includes personnel who are provided by a temporary help service, as defined in paragraph (14) [ (10) ] of this subsection.

(4) [ (2) ] Employer-- To determine [ In determining ] which of several persons is the employer of an individual, the comptroller will consider these factors [ which will be considered include ]:

(A) who exercises direct control over the details of how the employee performs the work [ is performed by the employee ];

(B) who pays the employee's salary;

(C) who withholds applicable federal taxes from the employee's salary;

(D) who provides employment-related benefits such as health insurance, sick leave, vacation, or eligibility to participate in a retirement plan[ , sick leave, vacation, etc., to the employee ]; and

(E) who has the right to terminate the employment of the individual employee.

(5) [ (3) ] Garbage or other solid waste--Waste; refuse; sludge from a waste treatment plant, a water supply treatment plant, or an air pollution control facility; and other discarded material, including solid, liquid, semisolid, or contained gaseous material, that result [ resulting ] from residential, industrial, municipal, commercial, mining, and agricultural operations, and [ resulting ] from community and institutional activities. The term does not include any of the following:

(A) solid or dissolved material in domestic sewage; [ or ] solid or dissolved material in irrigation return flows; or industrial discharges that are subject to regulation by a permit issued pursuant to the Texas Water Code, Chapter 26;

(B) waste materials that [ which ] result from activities associated with the exploration for or [ , ] development[ , ] or production of oil, gas, geothermal resources, or any other substance or material that the [ regulated by the ] Railroad Commission of Texas regulates pursuant to Natural Resources Code, §91.101;

(C) any waste that [ which ] requires specific licensing under Health and Safety Code, Chapter 401, and the rules that [ adopted by ] the Texas Board of Health adopts under that law, which for the purposes of this section [ rule ] shall be referred to as radioactive waste;

(D) any substance that [ hazardous waste, as identified or listed as a hazardous waste by ] the administrator of the United States Environmental Protection Agency or [ by ] other appropriate federal or state agency identifies or lists as hazardous waste ; or

(E) industrial solid waste, as that term is defined in Health and Safety Code, Chapter 361, with the exception of industrial solid waste that [ which ] meets the definition of garbage or municipal solid waste.

(6) [ (4) ] Landscaping--The activity of arranging and modifying areas of land, natural scenery and other areas, such as indoor or outdoor patios, for aesthetic effect, considering the use to which the land is to be put. The term includes adding, removing, or arranging natural forms, features, and plantings, including vegetation, and other features to fulfill aesthetic requirements. It includes the application of soil, soil additives, and amendments to prepare or maintain the planting area. Some examples are garden planting or maintenance, arborist services, ornamental bush or shrub planting, tree planting or removal, tree surgery, pruning or spraying, and lawn sodding. The term does not include the addition of sprinkler systems, retaining walls, ponds, pools, or fences, or other construction activities or services provided by landscape designers or landscape architects such as consultation, research, preparation of general or specific design or detail plans, studies, specifications, or supervision, or any other professional services or functions within the definition of the practice of engineering or architecture. Landscaping services performed by landscape designers or landscape architects are taxable.

(7) [ (5) ] Lawn and yard maintenance-- To mow, trim, fertilize, water, or perform [ Mowing, trimming, fertilizing, watering and ] any other treatment or service [ which may be performed ] on private or commercial yards or lawns. It also includes maintenance of trees and plants whether inside or outside a building. Clearing [ The term does not include clearing ] land for buildings, and mowing power line , pipeline, or highway rights-of-way, are not lawn and yard maintenance services. [ pipeline rights-of-way, or maintenance on land belonging to a governmental entity when the service is required by the governmental entity. ]

(8) New Construction--All new improvements to real property, including initial finish-out work to the interior or exterior of the improvement. An example is a multiple story building that has had only its first floor finished and occupied. The initial finish-out of each additional floor before initial occupancy or use is new construction. New construction also includes the addition of new usable square footage to an existing building. Examples include the addition of a new wing onto an existing building or the addition of a new mezzanine level within an existing building. Reallocation of existing square footage inside a building is remodeling and does not constitute the addition of new square footage. For example, the removal or relocation of interior walls to expand the size of a room or the finish out of an office space that was previously used is remodeling. Raising the ceiling of a room or the roof of a building is not new construction if new usable square footage is not created.

(9) [ (6) ] Property management company--A person , including an affiliate of a property management company, who, for consideration, operates and manages all the activities at a property held by the owner for purposes of rental, including [ such as: ] an office building, mall , [ or other ] retail or office complex, [ an ] apartment complex, duplex, or home. In the context of this section [ rule ], the responsibilities of a property management company must include, but are not limited to, securing tenants, hiring and supervising persons who are responsible for [ employees for operation or ] upkeep of the property, receiving and applying revenues, and incurring and paying expenses derived from the operation of the property as directed by the owner. A corporation, limited liability company, partnership, trust, or estate is an affiliate of the property management company if either it or the management company owns at least an 80% interest in the other, or if both it and the management company are owned by a third person who has at least an 80% ownership interest in both. The term does not include a person who performs [ performing ] taxable services at a manufacturing facility or at a property held by the owner for purposes other than rental.

(10) Real property services--Services as set out in subparagraph (A) of this paragraph whether performed on residential or nonresidential property.

(A) Real property services are:

(i) landscaping;

(ii) lawn and yard maintenance;

(iii) removal or collection of garbage, rubbish, or other solid waste;

(iv) building or grounds cleaning, janitorial, or custodial services;

(v) structural pest control service; or

(vi) surveying of real property.

(B) Real property services does not include:

(i) a service that is listed under subparagraph (A) of this paragraph if the service is purchased by a contractor, developer, builder or other person acting as a builder, and if the service is purchased in connection with the construction of a new residential structure or other improvement that is immediately adjacent to the new residential structure and that is used in the occupancy of the structure. This exclusion does not apply to services that are performed on property that is used as a sales office;

(ii) surveying of real property if the service was purchased by a real property owner during the period of October 1, 1999 through September 30, 2001 and if the service was purchased in connection with the construction of a new residential structure or other improvement that is immediately adjacent to the new residential structure and that is used in the occupancy of the structure;

(iii) the collection and removal of items excluded from the definition of garbage as set out in paragraph (5) of this subsection.

(11) [ (7) ] Residential or nonresidential building or grounds cleaning, janitorial, or custodial services--The activities of keeping the inside and outside premises of a building clean, orderly, and functional, including performing minor adjustments, maintenance, or repairs. Examples include, but are not limited to: window washing; floor, wall, and ceiling cleaning; collection of waste on the premises, whether from inside a building or on the grounds; chimney or duct cleaning; lighting maintenance, such as bulb and fuse replacement; the cleaning, disinfecting, and restocking of restrooms or lounge areas; cleaning or washing sidewalks, parking garages, or parking lots; and pool cleaning and maintenance. The term does not include activities such as painting , [ ; ] wallpapering , [ ; ] or performing significant repairs . Domestic [ ; nor domestic ] services such as those of a baby-sitter, maid , or cook are not included in this term when provided by an individual who is an employee of [ employed by ] a private household and the services are [ to provide domestic services ] for the benefit of the household.

(12) [ (8) ] Structural pest control services--Activities that are regulated by the Texas Structural Pest Control Board and that are performed to: [ for the purpose of ]

(A) identify, prevent, control, or eliminate, [ identifying, preventing, controlling, or eliminating, ] by use of chemical or mechanical means, infestation of any of the following:

(i) [ (A) ] insects, spiders, mites, ticks, ants, bees, and other related pests, wood infesting organisms, rodents, weeds, nuisance birds, or any other obnoxious or undesirable animals that [ which ] may infest households, railroad cars, ships, docks, trucks, airplanes , or other structures or their contents; or

(ii) [ (B) ] pests or diseases of trees, shrubs , or other plantings in a park or adjacent to a residence, business establishment, industrial plant, institutional building, or street; and

(B) [ (C) ] inspect or evaluate [ the term "structural pest control services" includes related activities, such as inspection or evaluation concerning ] the nature or extent of an infestation , and to prepare related [ ; ] reports[ ; or performance of services to control pest or insect infestation ].

(13) [ (9) ] Surveying of real property--Activities [ performed ] to determine or confirm the boundaries of real property, or [ to determine or confirm ] the location of structures or other improvements in relation to the boundaries of the property by the use of relevant elements of law, research, measurement, analysis, computation, mapping , and land description. Examples include[ , but are not limited to, ] boundary recovery, residential surveying, lot surveying, title surveying, as-built title surveying, and right-of-way surveying. The term does not include searches of a [ activities performed after taxable surveying has been completed to search the ] surveyed area for items of archaeological or historic significance.

(14) [ (10) ] Temporary help service--An individual, company, or corporation that supplies personnel on a temporary basis to supplement a customer's existing work force and that falls within Labor Code, §93.001, the service is covered by Industry Group 7363, Group 736, Major Group 73 of the Standard Industrial Classification Manual, 1989[ , and includes an individual, company, or corporation that supplies personnel on a temporary basis to supplement a customer's existing work force ]. In the context of this section, such temporary personnel must perform a service that is normally performed by the customer's own employees; the customer must provide all supplies and equipment necessary; and the temporary personnel must be under the direct or general supervision of the customer to whom the help is furnished.

(b) Responsibilities of persons who provide [ providing ] real property services . [ on both residential and nonresidential real property. With the exception of terms defined by subsection (a)(6) and (10) of this section, ]

(1) Persons who perform [ persons providing services defined in subsection (a) of this section are performing real property services. Persons performing ] real property services must obtain a tax permit and collect and remit sales or use taxes on all charges for real property services.

(2) Persons who perform nontaxable services as described in subsection (a)(10)(B) of this section are not considered retailers under Tax Code, Chapter 151, and are not required to hold tax permits. Such persons are required to pay sales or use tax on all purchases of taxable items that are used to perform the nontaxable service.

(3) Persons who perform both real property services and nontaxable services are required to obtain a tax permit and must collect and remit sales or use taxes on all charges for real property services.

(4) To document that a service is a nontaxable service under subsection (a)(10)(B) of this section, a service provider's customer must prove by way of written invoices, contract, or other documentary evidence that the services are nontaxable real property services in that subsection. If the service provider does not have a written document, then the service provider must presume that the service is a taxable real property service and must therefore collect tax. If the customer has documentation to prove that the service qualifies as nontaxable service, then the customer may issue to the service provider an exemption certificate in lieu of paying tax or provide the documentation required to overcome the presumption. The certificate must sufficiently describe the service performed to document that the service falls within the exclusion identified in subsection (a)(10)(B) of this section and must state that the customer is liable for any additional tax that is due in the event that the comptroller determines that a taxable service was performed.

(c) Purchases for resale [ Resale certificates ].

(1) A properly completed resale certificate may be used to purchase tangible personal property tax free if the care, custody, and control of the property is transferred to the customer as part of the real property service. For example, a service provider who [ taxpayer ] purchases paper towels [ products ] to be left at the customer's premises when providing janitorial services, or who purchases garbage dumpsters to be left [ leave ] on the customer's premises as a part of the taxable garbage collection service[ . Taxpayer ] may purchase the paper towels or [ products and ] dumpsters tax free by issuing a resale certificate. Tax is due on the total amount the service provider charges to [ charged ] the customer, including charges [ amounts ] for the paper towels [ products ], dumpster, and [ for the ] services.

(2) A properly completed resale certificate may be issued for a service if the buyer intends to transfer the service to another as an integral part of a taxable service. A service will be considered an integral part of a taxable service if the service purchased is essential to the performance of the taxable service and without which the taxable service could not be rendered. See §3.285 of this title (relating to Resale Certificate; Sales for Resale).

(3) A properly completed resale certificate may be issued to purchase a taxable service tax free if the buyer intends to incorporate the service into tangible personal property that [ which ] will be resold. If the entire service is not incorporated into the tangible personal property, [ it will be presumed ] the service is subject to tax and [ the service ] will [ only ] be exempt only to the extent that the buyer can establish the value of that portion of the service that is [ actually ] incorporated into the tangible personal property. The buyer may not issue a resale certificate if [ If ] the buyer does not intend to incorporate the entire service into the tangible personal property, [ the buyer may not issue a resale certificate ] but [ he ] may claim credit at the time of sale [ of the tangible personal property ] for the portion of the service that is [ was actually ] incorporated into the tangible personal property.

(d) Exemption or direct payment exemption certificates.

(1) A person who provides [ Persons providing ] real property services may accept a properly completed exemption certificate in lieu of tax when the service is purchased by an exempt entity or a direct payment permit holder . See §3.322 of this title (relating to Exempt Organizations), §3.287 of this title (relating to Exemption Certificates), and §3.288 of this title (relating to Direct Payment Procedures and Qualifications).

(2) A person who provides real property services in a disaster area to repair damages may accept a properly completed exemption certificate in lieu of tax on labor to repair property damaged by the disaster, if the charge for labor is separately itemized. Tax is due on the materials.

(e) Certain exempted landscaping and lawn and yard services. Landscaping, lawn, and yard maintenance [ provided by persons under 18 years old or by persons 65 years old or older. Charges for the performance of landscaping, lawn, and yard maintenance ] services [ (subsection (a)(4) and (5) of this section) ] are exempt if performed by a self-employed individual whose total receipts from landscaping, lawn, or yard maintenance are $5,000 or less for the four most recent calendar quarters. The exemption does not apply to landscaping, lawn, and yard services performed by an employee or independent contractor hired by the self-employed individual. Services are presumed taxable until the service provider gives the purchaser a written statement that receipts for qualifying services did not exceed $5,000 in the four most recent calendar quarters. If the receipts exceed $5,000 in the four most recent calendar quarters, then the self-employed individual must collect sales tax on landscaping, lawn, or yard maintenance service beginning the first day of the next calendar quarter after the quarter in which the $5,000 threshold was exceeded. [ : ]

[(1) a self-employed person under 18 years of age whose total receipts from providing landscaping, lawn, or yard maintenance are $1,000 or less during either the preceding calendar quarter or the same calendar quarter of the preceding year; or]

[(2) an individual 65 years of age or older whose total receipts from providing landscaping or yard maintenance are $5,000 or less for the four most recent quarters].

(f) Landfill charges connected with garbage collection services. Persons who provide [ providing ] garbage collection services may not separate [ in the bill to their customers ] the charge for garbage collection from the charge for use of the landfill for the purpose of reducing the amount upon which tax must be collected. The charge paid by the service provider for access to the landfill, while not taxable to the service provider, is a necessary expense in providing the garbage collection service and is not excludable from the fee to the service provider's customer for garbage collection.

(g) Garbage removal facilities. When a city, county, or any other entity provides a facility where garbage may be left for later removal [ and which will, at another time, be moved ] to a landfill, the fee for [ charged to persons ] depositing garbage into such a facility is [ considered to be ] a charge for taxable garbage collection [ and is taxable ].

(h) Waste collection [ Garbage collection ] services [ that may be ] excluded from real property services. [ tax. Persons providing collection services for customers having ]

(1) Charges for waste collection services are presumed taxable unless the customer gives the service provider documentation that the waste is [ waste ] excluded from the definition of "garbage or other solid waste." The collection of waste excluded from the definition of "garbage or other solid waste" as provided in subsection (a)(5) of this section is not taxable. When such excluded waste is removed, the service provider should accept a written statement from the customer affirming that the waste is excluded from the definition of garbage or other solid waste. [ may accept an exemption certificate from the customer in lieu of tax. The exemption certificate must state the type of waste being excluded, and that either the waste to be collected is totally excludable or that the customer has both taxable and nontaxable waste and the customer will be responsible for accruing tax on that portion of the charge which represents taxable services. The customer may use any reasonable allocation for reporting tax on taxable services which is supportable by books and records ].

(2) When collecting both garbage as defined by subsection (a)(5) of this section and excluded waste, the service provider must collect tax on the total charge for the service unless:

(A) the charge for the removal of excluded waste is separately stated from charges for removing garbage or solid waste; or

(B) the service provider and the customer agree in writing that the customer will be responsible for accruing tax on that portion of the charge that represents taxable services. The customer may use any reasonable allocation for reporting tax on taxable services.

(i) Unrelated services.

(1) A service is [ will be considered as ] unrelated if:

(A) it is neither [ not ] a real property service, nor a service or labor taxable under another provision of the Tax Code, Chapter 151;

(B) it is [ not provided as a part of the taxable service and is ] of a type that [ which ] is commonly provided on a stand-alone basis; and

(C) the performance of the [ unrelated ] service is distinct and identifiable. Examples of [ an ] unrelated services that [ service which ] may be excluded from the tax base include maintenance charges that meet [ meeting ] the definition in §3.357 of this title (relating to [ Labor Relating to ] Nonresidential Real Property Repair, Remodeling , and Restoration ; Real Property [ , ] Maintenance[ , New Construction, and Residential Property ]), engineering studies, and architectural or landscaping design [ designs ].

(2) If a combination of [ When ] nontaxable unrelated services and real property services are performed under the same contract [ taxable services are sold or purchased for a single charge ] and the portion of the charges for real property [ relating to taxable ] services exceeds [ represents more than ] 5.0% of the total charge, then the parties must separately identify taxable and nontaxable services along with the charges that apply to each or else the total charge is presumed to be for real property services and is taxable. Both parties must retain documentation that clearly defines the work that is performed to show that, had the real property services and nontaxable services been performed independently, the charge for each would approximate the amount allocated. If [ The presumption may be overcome by the service provider at the time the transaction occurs by separately stating to the customer a reasonable charge for the taxable services. However, if ] the charge for the taxable portion of the services is not separately stated [ at the time of the transaction ], the service provider or the purchaser may later establish [ for the comptroller ], through documentary evidence, the percentage of the total charge that relates to nontaxable unrelated services. [ A customer may presume that a separately stated charge from a service provider for taxable services is reasonable, in the context of this section. ] The service provider's books must support the apportionment between taxable [ exempt ] and nontaxable [ nonexempt ] activities based on the cost of providing the service or on a comparison to the normal charge for each service if provided alone. If the service provider's apportioned charge for nontaxable [ charge for exempt ] services is unreasonable based on [ unreasonable when the overall transaction is reviewed, considering ] the cost of providing the service [ or a comparable charge made in the industry for each service ], the comptroller may [ will ] adjust the charges and either party may be held responsible for the additional taxes due [ assess the service provider the additional tax, penalty, and interest on the taxable services ].

(3) The sales price of a real property taxable service includes all charges for expenses related to the provision of that service whether separately stated. [ Charges for services or expenses directly related to or incurred while providing the taxable service are taxable and may not be separated for the purpose of excluding these charges from the tax base. ] Examples include charges for equipment, meals, telephone calls, hotel rooms, or airplane tickets.

(j) Governmental entities. Sales or use tax is due on charges for [ When ] garbage collection services that are provided by a governmental entity . However, no sales or use tax is due if the governmental entity provides garbage collection services [ without a specific charge being assessed, such as when this service is provided ] as a basic part of services funded by a tax or a set fee structure of the governmental entity . If [ , sales or use taxes are not due. This section does not apply if ] the fee is [ changes each billing period ] based on volume of waste or services provided to [ quantity of consumption of tangible personal property or service provided ] individual service recipients , then the garbage collection service is not considered to be a part of a set fee structure, and the fee is subject to sales or use tax .

(k) Local taxes. With the exception of garbage or other solid waste removal services, local sales and use taxes apply to services in the same way as they apply to tangible personal property. [ Generally, service providers must collect local sales taxes if their place of business is within a local taxing jurisdiction, even if the service is actually provided at a location outside that jurisdiction. However, transit sales taxes do not apply to services provided outside the boundaries of the transit area. If the service provider's place of business is outside a local taxing jurisdiction but the service is provided to a customer within a local taxing jurisdiction, local use taxes apply and the service provider is required to collect them. ]

(1) If a service provider has only one place of business, local sales tax must be collected based on the tax rate at the service provider's place of business, even if the service is performed at a different location, but the service provider should not collect transit authority sales tax if the service is performed at a location outside the boundaries of the transit area. If a service provider has multiple places of business, then the service provider must collect local sales tax based on the tax rate at the place of business from which the service is provided, regardless of the location where the customer's order was taken.

(2) If a service provider has a place of business that is outside the boundaries of a local taxing jurisdiction, then the service provider will be required to collect local use tax if the service is performed within the local taxing jurisdiction.

(3) A garbage or waste collection service provider must collect local taxes based on the tax rate of [ Local taxes for garbage or other solid waste removal services are allocated to ] the local taxing jurisdiction where the [ in which the garbage or other solid waste is located when its ] collection or removal of garbage or other solid waste occurs [ begins ].

(l) Responsibilities. For general information on the collection and reporting responsibilities of providers and purchasers of taxable services, see §§ 3.252, 3.253, 3.286, 3.374, 3.375, 3.424, and 3.425 of this title (relating to Collection and Allocation of County Tax; County Use Tax; Seller's and Purchaser's Responsibilities; Collection and Allocation of the City Sales Tax; City Use Tax; Collection and Allocation of Transit Sales Tax; and Transit Use Tax) [ Imposition of the Sales Tax; Collection by Retailer; Bracket System Formula; Determining City Tax, Administration of Use Tax; Collection by Retailer, Imposition of Sales Tax, and Administration of Use Tax; Imposition and Collection) ].

(m) Use tax. If a seller of a taxable service is not engaged in [ doing ] business in Texas or in [ a ] specific local taxing jurisdictions [ jurisdiction ] and is not required to, or does not voluntarily, collect and report [ the applicable ] Texas state and/or local tax, it is the Texas customer's responsibility to report and pay the state and/or local use tax directly to this office.

(n) Property management companies.

(1) Employees permanently assigned to one rental property are considered employees of that property if [ when ] the property manager is reimbursed by the property owner for the salaries of the employees on a dollar-for-dollar basis. On managed rental properties, the employees remain assigned to the property while employed by successive owners or management companies. The reimbursement charge for taxable services performed on the [ a managed rental ] property by those assigned [ management company ] employees is [ assigned to it will ] not [ be ] taxable. However, if these same employees provide real property services for other properties, the property manager must collect tax on the total charge for those services. The management company owes tax on the [ purchase ] price of all taxable items purchased [ and provided to the employees providing services on managed rental property ].

(2) Property management companies whose employees provide taxable services as part of their overall management and operation of a rental property need not collect tax on those services if the [ their ] value of the taxable services is insignificant.

(A) Insignificant means that the value of the taxable service [ Such taxable services will be considered insignificant in any billing period in which their value ] is 5.0% or less of the amount charged by the management company for services in any billing period . The amount charged by the management company for taxable services is to be determined by deducting from the management company's total charge any mortgage payments made by the management company for the property owner and any amounts paid to persons other than employees of the management company for goods and services.

(B) If the value of the taxable services exceeds the 5.0% limit, the entire amount charged by the management company is [ will be considered ] taxable . All separately stated [ unless ] charges for taxable services are taxable. [ separately itemized and taxed as provided under subsection (i)(2) of this section. ]

(3) Purchases by the property management company for use by the property owner of taxable goods, labor, or services from third-party suppliers may be handled in either of the following ways:

(A) the management company may issue a properly completed resale certificate to the supplier and collect tax from the property owner on the itemized charge for the goods, labor, or services [ service ]; or

(B) the management company may pay tax to the supplier and collect from the property owner an amount equal to the total of the amount paid by the management company for the goods, labor, or services and the tax paid. Any amount represented as tax must be labeled as "tax reimbursement."

This agency hereby certifies that the proposal has been reviewed by legal counsel and found to be within the agency's legal authority to adopt.

Filed with the Office of the Secretary of State on March 11, 2003.

TRD-200301675

Martin Cherry

Chief Deputy General Counsel

Comptroller of Public Accounts

Earliest possible date of adoption: April 27, 2003

For further information, please call: (512) 475-0387