Private Letter Ruling

Ruling Number:P-1999-13
Tax Type:Kansas Retailers' Sales Tax
Brief Description:Customer representative voice and data communication services.
Approval Date:02/05/1999

Office of Policy & Research

February 5, 1999




The purpose of this letter is to respond to your letter dated January 19, 1999.

Your client, XXXXXXXXXXX. ("Company") is a leading provider of customer care solutions for large multinational companies. These customer care solutions encompass a wide range of telephone and computer based customer acquisition, retention and satisfaction programs designed maximize long-term value of the relationships between the Company's clients and customers. Such programs involve all stages of customer relationship and consist of a variety of customer service product support activities. This includes new product information, enrolling customers in clients programs, providing 24-hour technical and help desk support, resolving customer complaints and conducting satisfaction surveys. The Company works closely with its clients to rapidly design and implement a comprehensive solutions to their specific business needs.

Services are provided by a trained customer care representative who respond to customer inquiries on behalf of the Company's clients. The Company representatives provide a wide range of on going voice and data communications services and loyalty programs. In a typical inbound customer interaction, a customer calls a toll free number or sends an Internet message to request product, service or technical information or assistance. The Company’s system identifies each inbound call by its telephone number and routes the call to an appropriate representative who is trained for that particular client program. Upon receipt of the call, the representative's computer screen automatically displace the client specific product, service or technical information to enable the representative to assist the customer. The Company also extended its capabilities to incorporate multimedia technology for customer interactions, including e-mail and interactive video.

The Company typically enables long-term strategic relationships formalized by multiyear contracts with selected clients in the telecommunications, transportation, technology, government services, healthcare, financial services and utilities industries. The Company targets these industries because of their complex product and service offerings and large customer bases, which require frequent and increasingly sophisticated customer interactions. You requested advice as to the taxability of the services provided by the Company.

Kansas law imposes sales tax on the sale of tangible personal property and certain enumerated services.

It is the opinion of the Department that no imposition exists in the law to impose Kansas sales tax on the services as described in this letter.

The Company would be required to pay Kansas sales and compensating taxes on all purchases of tangible personal property and taxable services used or consumed by their business.

This private letter ruling is based solely on the facts provided in your request. If it is determined that undisclosed facts were material or necessary to make an accurate determination by the department, this ruling is null and void. This private letter ruling will be revoked in the future by operation of law without further department action if there is a change in the statutes, administrative regulations, or case law, or a published revenue ruling, that materially affects this private letter ruling.


Mark D. Ciardullo
Tax Specialist


Date Composed: 02/16/1999 Date Modified: 10/11/2001