Invoice-matching reports

Czech Republic: As of 1 January 2016, VAT payers must disclose the data contained in their invoices to the finance office via a new invoice-matching report.

The obligation to file invoice-matching reports affects everyone who is registered as a VAT payer in the Czech Republic. Legal entities will file these reports on a monthly basis, always within 25 days from the end of the calendar month, irrespective of whether their assessment period is monthly or quarterly. Natural persons will file the invoice-matching report depending on the time period for filing VAT reports that applies to them. The invoice-matching report must be filed (electronically, in the .xml format) whenever a VAT payer reports any value-added tax for the given period, or renders taxable services and supplies under the reverse charge regime, or claims any input tax deduction, or rendered performances under the special regime that applies to investment gold.

The reporting form will likely be divided into three sections: Part A serves to list performances received or rendered for which the taxpayer must report taxes. Part B serves to list performances received in those cases in which the place of performance lies within the Czech Republic. Part C serves as a control mechanism for conciliation with the VAT return.

One aspect of the invoice-matching report which may spell trouble is the fact that there will be a time lag for performances for which the tax return is to be filed by the recipient (acquisition of goods from other EU countries, acceptance of services from a provider who entertains no establishment in the Czech Republic). According to the official instructions, such performances will have to be reported irrespective of whether the taxpayer already avails of the relevant VAT invoice. By contrast, things have been made easier in the case of performances and supplies whose individual value does not exceed CZK 10,000: these may lumped together and reported in a single line on the form.

Taxpayers who do not file the regular invoice-matching report even within an additional time period granted by the tax authorities will be fined in the amount of CZK 50,000. In addition, the tax authorities may impose a fine of up to CZK 500,000 if the taxpayer’s failure to file the report is hampering or frustrating the administration of tax matters in a major way.

The website of the Finance Administration already contains the relevant form: Invoice-matching report form, along with preliminary instructions as to how to fill in the form.

Source: Finance Administration Finance ministry VAT Act (Act No. 235/2004 Coll., on value-added tax)

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