TITLE 34.PUBLIC FINANCE

Part 1. COMPTROLLER OF PUBLIC ACCOUNTS

Chapter 3. TAX ADMINISTRATION

Subchapter O. STATE SALES AND USE TAX

34 TAC §3.313

The Comptroller of Public Accounts proposes amendments to §3.313, concerning cable television service. The proposed amendments implement substantive changes due to the decision in Sharp v. Clearview Cable TV, Inc., 960 S.W.2d 424 (Tex.App.-Austin 1998, pet. denied) relating to equipment that may be purchased for resale by a cable television service provider, and due to the Telecommunications Act of 1996 as it relates to the federal preemption of local taxes on direct-to-home satellite cable television service. Subsections (d), (e), and (g) are amended accordingly. Nonsubstantive changes are made throughout the section to improve clarity and readability.

John Heleman, 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. Heleman 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 taxpayer 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 §151.0101(a)(2) and §151.0033.

§3.313.Cable Television Service.

(a) Cable television service. Cable television service is the distribution of video programming , with or without the use of wires , to subscribing or paying customers. The term includes direct broadcast satellite service (DBS), subscription television service (STV), satellite master antenna television service (SMATV), master antenna television service (MATV), multipoint distribution service (MDS), and multichannel multipoint distribution service (MMDS) , and any audio portion of a video program.

(b) Imposition of tax. The sale of cable television service and any services or expenses connected to the provision of the service are subject to the sales and use tax. Taxable charges include:

(1) (No change.)

(2) charges for video programming services;

(3) charges for taxable items, such as converters and descramblers, transferred to customers;

(4) - (6) (No change.)

(c) Deposits. A deposit that represents future payment for cable television service is part of the sales price of the service and is taxable when the deposit is used to pay for the service. A deposit paid to receive equipment such as a converter that is returned to the cable television service provider when the service is terminated [ customer returns the equipment ] is not taxable.

(d) Sales for resale [ Resale certificate ].

(1) Taxable services. A resale certificate may be used to purchase a taxable service[ , ] tax free if the service will be transferred as an integral part of a taxable cable television service. For example: if a [ seller of ] cable television service provider provides converters to its customers and a converter is [ who has a converter ] repaired by a third party , the cable television service provider [ , which converter is returned to the customer as part of the service, ] may give a resale certificate in lieu of paying tax on the purchased [ purchase the ] repair service [ tax free ]. See §3.285 of this title (relating to Resale Certificate; Sales for Resale).

(2) Tangible personal property. A 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 a part of the cable television service. For example, a cable television service provider may give a resale certificate to the seller of converters and remote controls that are provided to customers as part of the sale of the cable television service. See §3.285 of this title.

(e) Taxable purchases. A cable television service provider owes tax [ Tax is due ] on equipment and supplies that are not transferred to the care, custody, and control of its customer[ , ] but are used in providing the service. Equipment and supplies purchased out of state and brought or shipped into Texas for use in providing the service are subject to Texas use tax. See §3.346 of this title (relating to Use Tax). Credit will be allowed against the [ Texas ] use tax for any sales or use tax legally imposed and paid to another state. See §3.338 [ §3.340 ] of this title (relating to Multistate Tax Credits and Allowance of Credit for Tax Paid to Suppliers [ Multistate Tax Credits ]). For example , [ : ] a cable television service provider [ seller ] must pay tax on the satellite receiving and transmitting equipment, cables, and wiring that are not located on a customer's premises that are used to provide the [ in providing cable television ] service [ to a customer ].

(f) Real property rental. An owner of real property , such as an apartment complex or hotel , that [ who ] provides cable television service to its [ the ] residents or guests must collect sales tax on any charge attributable to the cable television service. If the owner does not charge the residents or guests for the service, the owner is the consumer of the service and must pay tax on all taxable items purchased.

(g) Local tax. The sale of cable television service occurs [ takes place ] at the point of delivery to the customer [ consumer ]. Cable [ Companies selling cable ] television service providers must collect local tax, if adopted, for the city, county, transit authority, and any [ or ] special purpose districts [ district ] in which delivery is made to the customer [ consumer ]. However, direct-to-home satellite cable television service programming transmitted or broadcast directly to a customer's premises, including a residence, hotel, or motel, without use of ground receiving or distribution equipment, except at the subscriber's premises or in the uplink process to the satellite is not subject to local tax under the Telecommunications Act of 1996, §602. Equipment used to provide direct-to-home satellite cable television service is subject to local sales and use taxes, unless otherwise exempted by this section.

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 February 1, 2007.

TRD-200700281

Martin Cherry

General Counsel

Comptroller of Public Accounts

Earliest possible date of adoption: March 18, 2007

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