SAP Implementation Technical Bulletin

Transcription

1 Utility Consolidated Billing Sales Tax Rate Changes (Update - 3) Impacts both New York and Pennsylvania Upon implementation of National Fuel Gas Distribution Corporation s ( NFGDC or Company ) new billing system, ESCOs and NGSs will be required to provide sales tax rates via EDI 1 to be applied to the ESCO/NGS s portion of the customer s bill under the Utility Consolidated Billing (UCB) Model. This change does not affect Dual Billing or Marketer Consolidated Billing (Single Retailer) in New York. The AMT*9M - Customer's Tax Rate for ESCO Charges 1 segment ( Residential ) and AMT*9N - Customer's Tax Rate for ESCO Charges 2 segment ( Commercial ) in the 814E (Enrollment) and the 814C (Change) EDI transactions will be used by ESCOs/NGSs to communicate sales tax rates for Residential and Commercial (non-residential) customers, respectively. The current GTOP sales tax forms will be retired. At implementation, the existing sales tax rates for each customer in the current system will be transferred into the new system. Post implementation, Enrollment transactions submitted for customers to be billed under UCB without sales tax information will be rejected. Similarly, Change transactions switching customers into UCB without sales tax information will be rejected. Additionally, sales tax rates will no longer carry forward from Utility sales to ESCO commodity or from ESCO to ESCO; each time a customer switches suppliers the sales tax rates and any exemption percentages will be reset using the supplier s information. ESCOs and NGSs will need to provide the total sales tax rate to be applied to their charges; there is no need to provide separate component and/or exemption percentages. NFGDC will not support the REF*RP Portion Taxed Residential segments in the Enrollment or Change Transactions; transactions with those segments populated will be rejected or ignored. Similarly, NFGDC does not support use of the AMT*DP Monetary Amount (Tax Exemption Percent) segments in the Enrollment or Change Transactions because the ESCO/NGS can provide the effect of the exemption in the AMT*9M or AMT*9N segments. For example, for a Commercial (non-residential) customer that is totally tax exempt, the ESCO/NGS should provide a zero tax rate in the AMT*9N segment. Using this approach, it will not be necessary for ESCOs to use the AMT*DP segment to add or remove a customer s tax exemption. Note that ESCO/NGS sales tax information is applied only to that portion of the customer s bill, i.e. NFGDC uses its own sales tax information for delivery charges, as applicable. 1 Pennsylvania NGSs that do not use EDI may use the Company s web site to provide sales tax rates for SATC customers. 1 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

2 Calculating the Effective Sales Tax Rate Calculation of the sales tax rate can be a multi-step process, particularly in New York. The ESCO is responsible for determining the applicable sales tax rate based upon publicly available tax rate information, the customer s tax jurisdiction, exemptions, customer classification and mixed use, if any. In New York, sales tax is assessed at the state and county levels and can be assessed at the municipality and school district levels. The calculation is somewhat simpler for Pennsylvania because the sales tax rate does not vary by location. The New York State Department of Taxation and Finance (DTF) provides a web site that may be used by ESCOs to help calculate the applicable sales tax rate (excluding school district tax) based upon the customer s street address. The URL for the Sales Tax on Utilities Jurisdiction and Rate Lookup is Be aware that DTF s web site does not have information indicating whether a location is residential or non-residential so it provides results for both outcomes. Additionally, the web site does not indicate if there are any Exemptions in place for the Customer, i.e. whether a TP- 385, ST-121 or other form of exemption is present. ESCOs should click on instructions and limitations for use before looking up an address. Be aware that DTF gives no assurance that their information is correct. When identifying what you would like to look up, be sure to select Sales Tax on Utilities Jurisdiction and Rates. Then enter the street address and click on Look Up Address. 2 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

3 The DTF web site will respond similar to what is shown below: Based upon the above information (presuming no school district tax), the ESCO should communicate sales tax rates as follows in Enrollment and Change EDI transactions: If the customer was Residential, AMT~9M~.0475 If the customer was Commercial, AMT~9N~.0875 If the customer was mixed use, e.g. 50% Residential & 50% non-residential, the effective sales tax rate would be calculated as follows: 50% * % * 8.75% = 6.75% therefore, AMT~9N~.0675 (note: even with partial Residential use, the tax rate should be provided in the AMT*9N segment.) If the customer was Commercial but had a 40% exemption at the county level, the ESCO through other means would have knowledge that the DTF provided rate of 8.75% consisted of state sales tax rate at 4% and county sales tax rate at 4.75%. The effective sales tax rate would be calculated as follows: (100% - 40%) * % = 6.85% therefore, AMT~9N~.0685 The above examples are merely a subset of all the potential outcomes, but in all cases, the ESCO/NGS bears all responsibility for determining the effective sales tax rate to be provided by the ESCO/NGS that will be used to calculate sales tax on the ESCO/NGS portion of the customer s bill. 3 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

4 EDI Matters To recap the discussion above, the following changes to NFGDC s EDI Implementation to support the billing of sales tax on the ESCO/NGS portion of the customer s bill under the UCB model: When enrolling a customer, the ESCO will be required to use AMT*9M - Customer's Tax Rate for ESCO Charges 1 segment or AMT*9N - Customer's Tax Rate for ESCO Charges 2 segment in the 814E Transaction to communicate sales tax rates for Residential and Commercial (non-residential) customers, respectively. When changing sales tax information for an existing customer, the ESCO will be required to use AMT*9M - Customer's Tax Rate for ESCO Charges 1 segment or AMT*9N - Customer's Tax Rate for ESCO Charges 2 segment in the 814C Transaction to communicate sales tax rates for Residential and Commercial (non-residential) customers, respectively. In both the 814C and 814E transactions, the Company will not support use of the REF*RP segment or AMT*DP segments; 814E and 814C transactions with these segments populated will be rejected or ignored In the 814C transactions, the REF*TD segment is necessary to indicate which sales tax rate segment will be changing, e.g. REF*TD*AMT9M to indicate sales tax rate changes for a Residential customer and REF*TD*AMT9N for a Commercial (non-residential) customer. Additionally, 814C and 814E transactions will be rejected under the following circumstances: Both the AMT*9M and AMT*9N segments are populated. 2 o NFGDC s EDI implementation requires that one or the other be populated. The net effective sales tax rate (adjusted for Residential use) for mixed use customers should be communicated in the AMT*9N segment and the AMT*9M segment should be left blank. Both the AMT*9M and AMT*9N segments are left blank. 3 Either the AMT*9M or AMT*9N segments contain values that indicate a sales tax rate above an upper limit set in response to the highest sales tax rate permissible in the service territory. The provided REF*TD segment reason for change code (AMT9M / AMT9M) is not consistent with the segment provided (AMT*9M / AMT*9N). The proper form for sales tax information in 814C and 814E transactions is as follows: 2 If an ESCO/NGS populates both segments with zero sales tax rates, e.g. AMT~9M~0.0 and AMT~9N~0.0, the Company will interpret the transaction to mean that the customer is exempt from sales tax for the ESCO/NGS portion of the customer s bill. 3 For non-ucb customers, Enrollment or Change transactions with blank AMT*9M and AMT*9N segments will be accepted. 4 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

5 AMT*9M contains a numeric value indicating a sales tax rate between 0% (exempt) and 20% with the AMT*9N, REF*RP and AMT*DP segments left blank/not sent. AMT*9N contains a numeric value indicating a sales tax rate between 0% (exempt) and 20% with the AMT*9M, REF*RP and AMT*DP segments left blank/not sent. At Implementation of the new billing system, ESCO/NGS sales tax rates will not be provided in the 814E Enrollment Accept Response or the 814C Account Change Accept Response but will be provided in analogous web files. These web files are explained below in the Web File (non-edi) Matters section of this bulletin. Change Request for Residential Sales Tax Rate Change to 4.5% submitted on 9/20/2015 ST*814*0001! BGN*13* * ! N1*SJ*ESCO NAME*1* ! N1*8S*NATIONAL FUEL GAS*1* ! N1*8R*JON D. KARDASHIAN! LIN* A051*SH*GAS*SH*CE! ASI*7*001! REF*12* ! REF*TD*AMT9M! REF*AMT*9M*.045! SE*11*0001! Transaction Set header; transaction defined is an 814; control number assigned by originator Transaction is a Request; Unique id number for this transaction; transaction creation date ESCO Name & DUNS number Utility Name & DUNS number ESCO Customer Name Unique transaction reference number, change pertains to gas service Action is a Change Request Utility Account Number Change Reason Code Change Customers Tax Rate for ESCO Charges Tax Rate Used to Calculate Taxes Applicable to ESCO Charges Transaction Set trailer; segment count; control number 5 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

6 Web (non-edi) Entry Pennsylvania NGSs that do not use EDI and grandfathered New York Direct Customers may enter customer sales tax rates for billing via web entry screens if they utilize the UCB billing model. Sales tax rate validation rules will be analogous to those applied to Enrollment and Change EDI transactions. A more detailed explanation of Web (non-edi) Entry will be provided in a subsequent technical bulletin. 6 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

7 Web File (non-edi) Matters Accessible from the General Information Files link on the Services For Marketers, Producers & Suppliers web page at: NFGDC provides a set of files (hereinafter, web files ) 4 that may be helpful to ESCOs/NGSs for the purpose of calculating sales tax rates applicable to customers. ESCOs and NGSs may use this information at their own risk; they do not substitute for information obtained directly from the tax jurisdictions. The files are not authoritative and are for information purposes only, and do not substitute for the ESCO/NGS independent determination of the sales tax rate applicable to its customer. These files reflect the information used by the Company for municipal/tax jurisdictions within its service territory for application services for which it applies sales tax, including a limited history of effective days for tax rate changes. Description Filename Retention/update Period County table TBSL3410.DAT refreshed monthly County sales tax rate table TBSL3416.DAT refreshed monthly Town table TBSL3411.DAT refreshed monthly Town sales tax rate table TBSL3417.DAT refreshed monthly 4 Some web files may not be ready at go-live. As necessary, workaround solutions will be provided until the web files are available. 7 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

8 School district table TBSL3412.DAT refreshed monthly School District sales tax rate table TBSL3418.DAT refreshed monthly State sales tax rate table TBSL3419.DAT refreshed monthly The files are delimited by semi-colons and may be downloaded for use in commonly available software. For example, the School District Table (as of 3/26/2015) contains the following information: BATV;BATAVIA HORN;HORNELL LACK;LACKAWANNA NIAF;NIAGARA FALLS As of the same date, the sales tax rates and history are as shown below. For example, BATV refers to the Batavia School District and since 3/1/1986, the school tax component of sales tax rate applicable to customers in this school district is 3%. BATV; ; BATV; ; HORN; ; HORN; ; LACK; ; ESCO/NGS Customer Sales Tax Changes - September 3, 2015

9 LACK; ; NIAF; ; Additionally, NFGDC provides 3 web files that are accessible from the Supplier / Customer Download Files link on the Services For Marketers, Producers & Suppliers web page at: that may be used to verify that ESCO/NGS sales tax rates provided via EDI have been accepted. The first web file, provided in response to a successful enrollment, will enable an ESCO/NGS to confirm whether the tax rate provided in the enrollment request has been accepted. The file also contains general customer information including the tax jurisdiction and a Sales Tax Exemption status indicator to communicate whether or not the Company has an exemption for the customer on file. The Company s exemption is not transferrable; the ESCO/NGS should contact the customer to obtain an exemption for its files. File Layout New customers general customer information (STBA/SATS file A0) Marketer id 7 ch Aggregation group id 9 ch Ratepayer billing id (RBA) 9 ch Cust last name 20 ch Cust first name 1 Cust middle initial Premises Address 80 ch Mail address 1 35 ch Mail address 2 35 ch Mail zip code 9 ch State code County code County name 15 ch Town code 4 ch Town name 25 ch School district code 4 ch School district name 15 ch Revenue class Budget plan yes/no Direct pay yes/no Service class Billing control Billing control effective date Account baseload 7 ch Account degree day factor 9 ch (5.3) Sales Tax Exempt ESCO Provided Sales Tax Rate 6 ch (numeric 1.4) 9 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

10 The second web file provided by NFGDC, the Aggregation Group Assignment Report, is the customer list by group and is reflective of the NFGDC billing database. This information is available as a report for on-line viewing (file T0) and a file for downloading (file J0). File Layout Aggregation group assignments (file J0) Marketer id 7 ch Aggregation group id 9 ch Assignment status code Ratepayer billing id (RBA) 9 ch Assignment start reference date Assignment start billing date Assignment end reference date Assignment end billing date Customer last name 20 ch Customer first name 1 Customer middle initial Revenue class Service class Marketer Rate Code (12 occurrences) Marketer Rate Effective Dates 8 ch (12 occurrences) Marketer Late Payment Code Budget plan yes/no Current Service Class County Code Town Code 4 ch School District Code 4 ch Capacity Release Indicator Current Bill Control Number Sales Tax Exempt ESCO Provided Sales Tax Rate 6 ch (numeric 1.4) 10 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

11 The third web file provided by NFGDC, the Daily Aggregation Assignment Changes, is the customer detailed change list by group and is reflective of the NFGDC billing database. This information is available as a file for downloading (file J1). Daily Aggregation Assignment Changes (file J1) Marketer id 7 ch Aggregation group id 9 ch Assignment status code Ratepayer billing id (RBA) 9 ch Assignment start reference date Assignment start billing date Assignment end reference date Assignment end billing date Customer last name 20 ch Customer first name 1 Customer middle initial Revenue class Service class Check digit Marketer Rate Code (12 occurrences) Marketer Rate Effective Dates 8 ch (12 occurrences) Marketer Late Payment Code Budget plan yes/no Current Service Class County Code Town Code 4 ch School District Code 4 ch Capacity Release Indicator Current Bill Control Number Sales Tax Exempt ESCO Provided Sales Tax Rate 6 ch (numeric 1.4) Questions concerning application of Sales Tax should be directed to Transportation Services at (716) or by TSD-Billing@natfuel.com. 11 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

12 Frequently Asked Questions (FAQs) 1) Will the use of AMT*9M for Residential Tax Rate and AMT*9N Commercial Tax Rate now be required for UCB enrollments? With the limited exception of Pennsylvania NGSs or grandfathered New York Direct Customers that do not use EDI, use of the AMT*9M or AMT*9N segment of Enrollment or Change EDI transactions will be required. 2) How will Pennsylvania NGSs or grandfathered New York Direct Customers that do not use EDI use the AMT*9M or AMT*9N segment of Enrollment or Change EDI transactions? A secure web entry screen will be provided to provide a means for Pennsylvania NGSs and grandfathered New York Direct Customers that do not use EDI to enter sales tax rates (along with other billing information). The entry screens will validate entries following the rules/processes applicable to use of the AMT*9M or AMT*9N segment of Enrollment or Change EDI transactions. 3) Where can an ESCO/NGS inquire/confirm their current Sales Tax Rate for their End Use Customer? NFGDC provides 3 web files that may be used to verify that ESCO/NGS sales tax rates provided via EDI have been accepted. These files are accessible from the Supplier / Customer Download Files link on the Services For Marketers, Producers & Suppliers web page at: For further details, see the Web File (non- EDI) Matters discussion above. 4) How does an ESCO/NGS set an account to be tax exempt? The ESCO/NGS should submit an effective tax rate that reflects the portion of a customer s account that is tax exempt in the AMT*9M or AMT*9N segment of Enrollment or Change EDI transactions. 5) Will NFGDC support the AMT*DP segment in Enrollment and/or Change EDI Transactions? No. By submitting an effective tax rate that reflects the sales tax exemption for a customer s account in the AMT*9M or AMT*9N segment of Enrollment or Change EDI transactions, the ESCO/NGS can accomplish the same sales tax result. 6) What happens if an ESCO/NGS submits an Enrollment or Change Transaction that populates AMT*DP segment? The transaction will either be rejected or the contents of AMT*DP segment will be ignored. 12 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

13 7) How does an ESCO/NGS remove tax exemption from an account? The ESCO/NGS should submit an effective tax rate that no longer reflects the customer s tax exemption in the AMT*9M or AMT*9N segment of a Change EDI transaction. 8) How does an ESCO/NGS change a tax rate on an account? The ESCO/NGS should submit the new sales tax rate in the AMT*9M or AMT*9N segment of a Change EDI transaction. 9) How does an ESCO/NGS set an account with a portion to be taxed Residential? The ESCO should submit an effective tax rate that reflects the portion of a customer s account that should be taxed at a Residential rate in the AMT*9N segment of Enrollment or Change EDI transactions. 10) Will NFGDC support the REF*RP segment in Enrollment and/or Change EDI Transactions? No. By submitting an effective tax rate that reflects the portion of a customer s account that should be taxed at a Residential rate in the AMT*9N segment of Enrollment or Change EDI transactions, the ESCO/NGS can accomplish the same sales tax result. 11) What happens if an ESCO/NGS submits an Enrollment or Change Transaction that populates AMT*9M, AMT*9N and REF*RP to bill an account at a sales tax rate that reflects some Residential use? The transaction will be rejected or ignored. 12) How does an ESCO/NGS remove the portion taxed Residential on an account? The ESCO/NGS should submit an effective tax rate that no longer reflects the portion tax Residential in the AMT*9N segment of a Change EDI transaction. 13) Does NFGDC require the formatting to be in a decimal (i.e.; 8% = 0.08 on the Change Transaction)? Are the rules the same for NY and PA? The New York EDI Standards require the sales tax rate to be formatted in decimal format. Since NFGDC uses New York EDI Standards in its Pennsylvania territory, the rules are the same for both states. 14) Will NFGDC continue to use the current GTOP Sales Tax Change Request Forms? No. These forms will be retired when the new billing system is implemented and they will be removed from the GTOP. 13 ESCO/NGS Customer Sales Tax Changes - September 3, 2015

14 15) With regard to the Utility Combined Billing Sales Tax Rate Changes, what happens if a taxing jurisdiction changes their tax rate? Will ESCOs/NGSs be responsible for sending change requests for every customer in that jurisdiction? Yes. Keep in mind that existing rates are being transitioned into the new system, however. The changes apply to prospective enrollments. Understanding and applying the tax rules, particularly in New York, is part of doing business. 16) If there was a general change in the tax rules, for example, if Pennsylvania changes their state tax rate would ESCOs/NGSs need to send 814 Change transactions for every customer impacted by a general change? In the case of general changes, it is possible that circumstances may allow for other approaches but until such changes present themselves, it is speculative to predict what actions could or would be taken. 14 ESCO/NGS Customer Sales Tax Changes - September 3, 2015