Current through Register Vol. 49, No. 9, September, 2024
I.
Introduction
To encourage growth in Arkansas's tourism industry, Act 291 was
passed by the 81st General Assembly in 1997 and amended in 1999, 2001 and 2005.
The legislation's purpose is to stimulate expansion of Arkansas's tourism
industry by offering economic incentives to qualified private development
projects in the form of sales and income tax credits. Since the intent is to
generate additional tourist traffic to Arkansas, each proposed project must
develop a marketing plan that targets 25% of its visitors from out-of-state and
meet other requirements. See Arkansas Code Annotated §
15-11-501 et
seq.
For more information, please contact:
Arkansas Department of Economic Development
Business Development Section
One Capitol Mall
Little Rock, AR 72201
(501) 682-7675
II.
Definitions
A. "Agreement" means an agreement entered
into pursuant to §
15-11-506, by and between the director and an approved
company, with respect to a tourism attraction project;
B. "Approved company" means any eligible
company that is seeking to undertake a tourism attraction project and is
approved by the director pursuant to §
15-11-505 and §
15-11-506;
C. "Approved costs"
mean:
1. Obligations incurred for labor and to
vendors, contractors, subcontractors, builders, suppliers, delivery men, and
material men in connection with the acquisition, construction, equipping, and
installation of a tourism attraction project;
2. The costs of acquiring real property or
rights in real property in connection with a tourism attraction project, and
any costs incidental thereto;
3.
The cost of contract bonds and of insurance of all kinds that may be required
or necessary during the course of the acquisition, construction, equipping, and
installation of a tourism attraction project which is not paid by the vendor,
supplier, delivery man, contractor, or otherwise provided;
4. All costs of architectural and engineering
services, including, but not limited to, estimates, plans and specifications,
preliminary investigations, and supervision of construction and installation,
as well as for the performance of all the duties required by or consequent to
the acquisition, construction, equipping, and installation of a tourism
attraction project;
5. All costs
required to be paid under the terms of any contract for the acquisition,
construction, equipping, and installation of a tourism attraction
project;
6. All costs required for
the installation of utilities in connection with a tourism attraction project,
including, but not limited to, water, sewer, sewage treatment, gas,
electricity, and communications, and including off-site construction of utility
extensions paid for by the approved company; and
7. All other costs comparable with those
described in this subsection.
D. "Director" means the director of the
Arkansas Department of Economic Development or the director's designated
representative;
E. "Eligible
company" means any corporation, limited liability company, partnership,
registered limited liability partnership, sole proprietorship, or business
trust, or any other entity that invests a minimum of five hundred thousand
dollars ($500,000) in a high unemployment county or one million dollars
($1,000,000) in any other county for the purpose of constructing, operating or
intending to operate a tourism attraction project, whether owned or leased,
within the state that meets the standards promulgated by the director pursuant
to §
15-11-504;
F. "Final
approval" means the action taken by the director authorizing the eligible
company to receive inducements under §
15-11-507 and Section 5 of Act 1135
of 1999;
G. "High unemployment"
means an unemployment rate equal to or in excess of one hundred fifty percent
(150%) of the state's average unemployment rate for the preceding calendar year
as specified by statewide annual labor force statistics compiled by the
Arkansas Employment Security Department, when the state's annual average
unemployment rate is six percent (6%) or below. When the state's annual average
unemployment rate is above six percent (6%), "high unemployment" means equal to
or in excess of three percent (3%) above the state's average unemployment rate
for the preceding calendar year as specified by statewide annual labor force
statistics compiled by the Arkansas Employment Security Department.
H. "Increased state sales tax liability"
means that portion of an approved company's reported state sales (gross
receipts) tax liability resulting from taxable sales of goods and services to
its customers at the tourism attraction for any monthly sales tax reporting
period after the approved company provides the certification required by §
15-11-507(b) of act 1135 of 1999, which exceeds the reported state sales tax
liability for sales to its customers for the same month in the calendar year
immediately preceding such certification. If an approved company purchases an
existing tourism attraction which was selling goods and services at the time of
purchase and which may or may not have been entitled to the benefits of this
subchapter prior to such purchase, the 'increased state sales tax liability'
resulting from any investments in the tourism attraction by the new owners
means that portion of the approved company's reported state sales (gross
receipts) tax liability resulting from taxable sales of goods and services to
its customers at the tourism attraction for any monthly sales tax reporting
period after the approved company provides the certification required by §
15-11-507(b) of act 1135 of 1999, which exceeds the reported state sales tax
liability for sales made by the seller of the tourism attraction for the same
month in the calendar year immediately preceding such certification. The
prohibitions against disclosure of confidential tax information provided in
§
26-18-301 shall not apply for purposes of computing the credit
available.
I. "Inducements" means
the Arkansas sales tax credit as prescribed in §
15-11-507 and/or the
Arkansas income tax credit as prescribed in Section 5 of Act 1135 of
1999;
J. "Investment Threshold"
means the minimum amount of eligible project costs that must be incurred in
order to qualify for eligibility;
K. "New full-time permanent employee" means a
position or job which was created as a result of a tourism attraction project,
and which is filled by one (1) or more employees or contractual employees who
were Arkansas taxpayers during the year in which the tax credits or incentives
were earned or claimed. The employee or employees must work an average of at
least thirty (30) hours per week. Provided, however, in order to qualify for
the provisions of this subchapter, a contractual employee must be offered a
benefits package comparable to a direct employee of the business seeking
incentives;
L. "Payroll" means the
total taxable wages, including overtime and bonuses, paid during the preceding
tax year of the approved tourism attraction to the new fulltime permanent
employees hired after the date of the signed financial incentive
agreement;
M. "Tourism attraction"
includes:
1. A cultural or historical
site;
2. A recreational or
entertainment facility;
3. An area
of natural phenomenon or scenic beauty;
4. A theme park;
5. An amusement or entertainment
park;
6. An indoor or outdoor play
or music show;
7. Botanical
gardens; and
8. Cultural or
educational centers.
N.
"Tourism attraction" does not include:
1.
Lodging facilities, unless the facilities constitute a portion of a tourism
attraction project and represent less that sixty percent (60%) of the total
approved costs of the tourism attraction project, or unless the project meets
the special rules outlined in Section 6(a) and Section 6(b) of Act 1135 of
1999;
2. Facilities that are
primarily devoted to the retail sales of goods, unless the goods are created at
the site of the tourism attraction project or if the sale of goods is
incidental to the tourism attraction project;
3. Facilities that are not open to the
general public;
4. Facilities that
do not serve as a likely destination where individuals who are not residents of
the state would remain overnight in commercial lodging at or near the tourism
attraction project;
5. Facilities
owned by the State of Arkansas or a political subdivision of the state;
or
6. Facilities established for
the purpose of conducting legalized gambling. However, a facility regulated
under §
23-110-101 et seq. or §
23-111-101 et seq. shall be a tourism
attraction for purposes of this subchapter for any approval project as outlined
in subsection (j)(1) of Act 1135 of 1999 or for an approved project relating to
pari-mutuel racing at the facility and not for establishing a casino or for
offering casino-style gambling.
O. "Tourism attraction project" or "project"
means the acquisition, including the acquisition of real estate by leasehold
interest with a minimum term of ten (10) years, construction, and equipping of
a tourism attraction; the construction and installation of improvements to
facilities necessary or desirable for the acquisition, construction, and
installation of a tourism attraction, including, but not limited to, surveys;
installation of utilities, which may include, water, sewer, sewage treatment,
gas, electricity, communications, and similar facilities; and off-site
construction of utility extensions to the boundaries of the real estate on
which the facilities are located, all of which are to be used to improve the
economic situation of the approved company in a manner that shall allow the
approved company to attract persons.
III.
To Qualify for the
Program a Business Must
A.
Be an eligible business, as defined by one or more of the following:
1. Cultural or historical site
2. Recreational or entertainment
facilities
3. Areas of natural
phenomenon or scenic beauty
4.
Theme parks
5. Amusement or
entertainment parks
6. Indoor or
outdoor plays or music shows
7.
Botanical gardens
8. Cultural or
educational center
9. A lodging
facility may qualify, but only if it meets one of the following tests:
(a) It must constitute a portion of a tourism
attraction project and represent less than 60% of the total approved costs of
the tourism attraction project; or
(b) If the approved cost for the lodging
facility exceeds $5,000,000 and one of the following is met:
(1) The lodging facility is attached to a
convention center containing a minimum of 75,000 square feet, or
(2) The lodging facility contains a minimum
of twelve thousand square feet of meeting or exhibit space.
B. Eligible
proposals do not have to be new construction projects. Expansion and/or
purchase of existing properties may be eligible. However, the amount of sales
tax credit can only be taken against the increased sales tax liability over and
above the amount paid by the business being sold or expanded for the
corresponding tax month of the previous year.
C. Privately owned facilities constructed on
state or federal lands (via a minimum 10-year lease) may be eligible.
D. Ineligible businesses include:
1. Lodging facilities (unless it meets the
tests described above);
2. Retail
sales facilities (unless the goods are created on-site or if sales are
incidental to the overall project);
3. Facilities not open to the general
public;
4. Facilities not likely to
attract overnight guests from outside the state who would stay in commercial
lodging near the attraction;
5.
Facilities owned by the State of Arkansas or its political
subdivisions;
6. Gambling
facilities (unless for approved pari-mutuel racing currently regulated under
Arkansas Code)
IV.
Powers and Duties of
the Department of Economic Development
A. The Director or designee of the Arkansas
Department of Economic Development will review each application, making certain
the project proposal meets the following minimum criteria:
1. the project shall have a marketing plan
designed to attract at least 25% of its visitors from out-of-state;
2. shall cost at least $500,000 in
high-unemployment counties or $1,000,000 in any other county;
3. shall have a significant and positive
impact on the State, including an analysis of whether the project will compete
directly with existing tourism attractions in the state;
4. shall produce sufficient revenues and
public demand to be operating and open to the public on a regular and
persistent basis;
5. shall be
likely to attract overnight guests from outside the state who would stay in
commercial lodging near the attraction;
6. shall not adversely affect existing
employment in the state;
7. and
other criteria that the Director may deem to apply.
B. Once the application has been reviewed,
the applicant will be notified in writing of the results of the
review.
C. Projects which have
filed an application for benefits under Act 291 of 1997 with the Arkansas
Department of Parks and Tourism prior to April 30, 1999 shall be eligible for
review by the Arkansas Department of Economic Development. Should the
applicants be approved for participation in the program after subsequent review
by the Director, the Director may choose to include the entire eligible costs
of the applicant as approved costs of the program, regardless of the date the
investment was made. Any tax credits received by these particular approved
companies shall be available to be applied, even retroactively, to sales taxes
collected by the approved companies after May 1, 1999.
D. Upon granting approval, the Director shall
enter into an agreement with an approved company with respect to its tourism
attraction project. The terms and provisions of each agreement shall include,
but shall not be limited to:
1. The amount of
approved costs, determined through negotiations with the Director and
applicant.
2. The eligibility date
for incurring project costs.
3. A
date by which the approved company shall have completed the tourism attraction
project (the Completion Date). Within 3 months after the Completion Date, the
approved company shall document the actual cost of the project through a
certification of such costs by an independent certified public accountant
acceptable to the Director. The Completion Date must be within 24 months
following the contract signature date, unless an extension is
granted.
4. A contract term of ten
(10) years commencing upon the completion date, provided that the completion
date occurs within (2) years of the date of the agreement. The term of the
agreement may be extended for a period of two (2) years by the Director if:
(i) such extension is also approved by the
Director of the Arkansas Department of Finance and Administration or
(ii) the approved company has failed to
complete the project as a result of unanticipated and unavoidable construction
delays or a change in business ownership.
5. In any sales tax reporting period during
which an agreement is in effect, if the increased state sales tax liability of
the approved company exceeds the state sales tax credit available to the
approved company, then the approved company shall pay the excess to the state
as sales tax;
6. Within 45 days
after the end of each calendar year, the approved company shall supply the
Director with such reports and certifications as the Director may request
demonstrating to the satisfaction of the Director that the approved company is
in compliance with the provisions of the Act; and
7. The approved company shall not receive a
credit against the Arkansas sales tax imposed by Ark. Code Ann. §
26-52-301 et seq. with respect to any calendar year if in any calendar year
following the first year of the agreement or the agreed upon completion date,
the project is not operating and open to the public on a regular and persistent
basis:
8. The Agreement shall not
be transferable or assignable by the approved company without the written
consent of the Director.
9. If the
approved company utilizes sales tax credits which are subsequently disallowed,
then the approved company will be liable for the payment to the Director of the
Department of Finance and Administration of all taxes resulting from the
disallowance of the credits plus applicable penalties and interest.
E. The Arkansas Department of
Economic Development's approval of any application is for content only. It does
not constitute approval of all items listed on the application or the project
plan. These items will be reviewed and either approved or ruled ineligible upon
an audit by the Revenue Division of the Department of Finance and
Administration (DF & A).
V.
Terms of the Incentive
Agreement
A. The following
types of expenses directly related to the tourism attraction project may be
included in the total approved costs that are eligible for sales tax credits:
1. Land (outright purchase or leasehold
interest with 10-year minimum term);
2. Buildings at the tourism attraction
site;
3. Land surveys and
architectural/engineering fees;
4.
Cost of contract bonds and insurance;
5. Installation of utilities paid by the
approved company (including off-site extensions that are project
specific);
6. Equipping of the
tourist attraction; and
7. Other
costs comparable to those described above can be approved on a case-by-case
basis.
B. Certain
approved costs will be recognized as pre-construction costs and will be
eligible for sales tax credits regardless of the date the costs were incurred.
Those are: project planning costs, feasibility studies, architectural fees,
right-of way purchases, and land.
VI.
Administration of
Benefits
A. State Income
Tax Credits (not eligible for lodging facilities)
1. Upon notification from the director that
an approved company has entered into a tourism attraction project a greement,
the Director of the Department of Finance and Administration shall provide the
approved company with such forms and instruction as are necessary to claim
those credits.
2. The approved
company shall certify the number and the payroll of the new fulltime permanent
employees to the Revenue Division of the Department of Finance and
Administration.
3. Upon
certification by the company, the Revenue Division of the Arkansas Department
of Finance and Administration shall authorize an income tax credit equal to
four percent (4%) of the payroll of the new fulltime permanent employees of the
approved tourism attraction project qualifying for benefits.
4. As used herein, the term "new full time
permanent employee(s)" shall mean a person who (i) is an Arkansas taxpayer in
the year the credits are claimed; (ii) is employed in a position or job created
by virtue of the project, and (iii) has worked an average of not less than
thirty (30) hours per week.
5. The
income tax credits may be applied against company income tax for the succeeding
nine (9) years or until the credit is entirely used, which ever occurs
first.
6. The Director shall
provide a copy of each agreement entered into with an approved company to the
Director of the Department of Finance and Administration.
B. Sales and Use Tax Credits
1. Upon receiving notification from the
Director that an approved company has entered into a tourism attraction project
agreement and is entitled to the sales tax credits provided by this Act, the
Director of the Department of Finance and Administration shall provide the
approved company with such forms and instructions as are necessary to claim the
credits.
2. An approved company
shall be entitled to a sales and use tax credit upon certifying to the Director
of the Department of Finance and Administration that it has met the investment
threshold for the county in which it is located. The Director of the Department
of Finance and Administration shall then issue a sales tax credit memorandum
for the appropriate amount (25% for projects located in high-unemployment
counties and 15% for all other projects) to the approved company. Subsequent
requests for credit for additional certified approved costs in excess of the
investment threshold shall be submitted annually for the term of the agreement
or until the project is completed, whichever occurs first.
3. The Director of the Department of Finance
and Administration may require proof of expenditures. Additional credit
memorandums may be issued as the approved company certifies additional
expenditures of approved costs.
4.
No sales tax credit memorandum shall be issued for any approved costs expended
after the expiration of two (2) years from the date the agreement was signed by
the Director and the approved company. However, the Director, with the advice
and consent of the Director of the Department of Finance and Administration,
may authorize sales tax credits for approved costs expended up to four (4)
years from the date the agreement was signed if the Director determines that
the failure to complete the project within two (2) years resulted from:
(a) Unanticipated and unavoidable delay in
the construction of the project;
(b) The project, as originally planned, will
require more than two (2) years to complete; or
(c) A change in business ownership or
business structure resulting from a merger or acquisition.
(1) The reasons listed above shall be brought
to the attention of the Director prior to the expiration of the initial two (2)
year period, and a request shall be made to the Director during the two (2)
years for an extension of time.
5. The credit memorandum issued may be used
to offset a portion of the reported state sales (gross receipts) tax liability
of the approved company for all sales tax reporting periods following the
issuance of the credit memorandum. One hundred per cent (100%) of the credit
may be used to offset increased sales tax liability during the first year, with
any unused credits carried forward for nine (9) additional years. The credits
are also subject to the following limitations:
(a) Only increased state sales tax liability
resulting from sales by the approved company may be offset by the issued
credit;
(b) All issued credit
memorandums shall expire at the end of the month following expiration of the
Agreement;
(c) The approved company
shall have no obligation to refund or otherwise return any amount of this
credit to the person from whom the sales tax was collected.
(d) By April 1 of each year, the Director of
the Department of Finance and Administration shall certify to the Director the
state sales and income tax liability of the approved companies receiving
inducements under this section, and the amount of state sales and income tax
credits taken during the preceding calendar year.
(e) The Director of the Department of Finance
and Administration may promulgate administrative regulations as are necessary
for the proper administration of this Act. The Director of the Department of
Finance and Administration may also develop such forms and instructions as are
necessary for an approved company to claim the sales and income tax credits
provided by this act.
(f) The
Director of the Department of Finance and Administration shall have the
authority to obtain any information necessary from the approved company and the
Director of Economic Development to verify that approved companies have
received the proper amounts of sales tax credits as authorized by this act; the
Director of the Department of Finance and Administration shall demand the
repayment of any credits taken in excess of the credit allowed by this
act.
(g) For amusement or
entertainment parks tourism attraction projects approved by the director
between April 1, 1999 and September 1, 1999, the director is authorized to
allow an exemption from the payment of sales and use taxes on certain purchases
of materials used in the construction of a building or buildings for housing
the tourism amusement or entertainment park and machinery or equipment to be
located in or in connection with the approved tourism attraction project. In
exchange for this exemption, the sales tax credit provided by this section
shall be ratably reduced by the amount of sales and use taxes that are not
collected due to the exemption granted under this subdivision. The sales tax
exemption shall expire on July 1, 2001. The Chief Fiscal Officer (The Director
of Finance and Administration) of the State shall have an audit conducted to
assure compliance with the exemption and sales tax credit exchange allowed in
this subdivision. In the event that it is found that the approved company
receiving the benefits contained in this section has failed to comply with the
conditions herein, that company shall be disqualified from receiving any
further benefits under this act and shall be liable for payment of such sales
and use taxes as may be due after the sales and use tax credits provided for in
this section are disallowed, plus interest.
C. Calculation of Arkansas Income Tax Credits
1. This program provides an Arkansas income
tax credit equal to four percent (4%) of the payroll of each new full-time
permanent employee.
2. The
calculations of the income tax credit is as follows:
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D. Calculation of Sales Tax Credit
1. This program offers a sales tax credit in
the amount of twenty-five percent (25%) of total project costs if the approved
tourism attraction is located in a high-unemployment area.
2. If the approved tourism attraction is
located in any other county the program offers a sales tax credit in the amount
of fifteen percent (15%) of the total project cost.
3. The calculation of the sales tax credit is
as follows:
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to view image