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CZ EPO — Check and File with Finanční správa

Signs Czech statutory filings with the company's qualified certificate and sends them to EPO — in test mode to check them, or for real to file them — and follows each filing to acceptance or rejection.

What it is for

EPO (Elektronická podání pro Finanční správu) is the Czech tax administration's electronic filing gateway, behind the MOJE daně portal. Besides its web forms and the data box, it has an interface for accounting software, the Podatelna EPO. That interface has no user accounts or API keys: a filing is the XML wrapped in a signature made with the filer's qualified certificate, and the signature is the identity.

This module adds EPO as a channel to the submission records of l10n_cssk_submission_base. Any statement that can be filed through that framework can then be:

• checked — signed and sent in EPO's test mode, which runs EPO's checks (signature, structure, content) and files nothing;
• filed — signed and sent for real, if the company allows it;
• followed — the potvrzení (receipt) and podací číslo (filing number) are kept, and EPO is asked periodically whether the tax office accepted or rejected the filing.

The Czech statements that produce an EPO file, and so can go through this channel, are among others:

The channel signs and sends whatever file the statement exported; it does not check that the file is an EPO form.

Legal background

Under the Tax Procedure Code, § 71 odst. 1 of Act No. 280/2009 Sb., a filing can be made electronically only as a data message signed in a way that has the effect of a handwritten signature, sent from the filer's data box or with another verified identity. A taxpayer with a data box set up by law, or with a duty to have its financial statements audited, must make form filings — tax returns among them — electronically (§ 72 odst. 6). A filing sent to the tax administration's technical equipment is made on the day it arrives, and the equipment confirms receipt with the time it was received (§ 73 odst. 1 and 3). This module uses the first route: the signed data message.

Setting it up

Everything below is visible only to users in the group Statutory submissions: file.

1. The certificate. Accounting → Configuration → Accounting → EPO certificates, then New. Upload the qualified certificate with its private key as a .p12 / .pfx file, as issued by the certification authority (I.CA, PostSignum, eIdentity), and its password. Include the issuer's intermediate certificates in the file. On saving, the module opens the file and shows the subject, issuer and validity; a file that cannot be opened is refused.
2. The company. Settings → Users & Companies → Companies, the company, page EPO podání, group Sending to EPO:

The rest of the EPO podání page (the signatory, the preparer, a representative) belongs to the Czech statutory forms and is described with them.

Whoever holds the certificate can file in the company's name, so the certificate file and password can be read or changed only by the filing group. Other accounting users see that a certificate exists, not its contents.

Checking and filing

The statement itself — a VAT return, say — is prepared and exported as usual. Then:

1. On the statement, File it (Podat where the statement is translated). With more than one channel installed, Odoo shows the statement's submissions instead of creating one; create one with the channel EPO — Finanční správa (signed, direct). The channel is offered only when the company's fiscal country is Czechia. Marking the statement submitted also opens a submission, on the channel Authority portal — filed by hand; while it is a draft you can switch its channel to EPO instead.
2. Check with EPO. The file is signed and sent in test mode. The result is stored on the submission, page EPO check: No errors, Warnings only or Errors, with EPO's list of messages and its answer as an XML attachment. A check never files and never changes the submission's state; you can repeat it as often as you like.
3. Queue, then Send now (or wait for the scheduled job, which sends queued submissions every five minutes). This files for real and is refused unless Allow filing through EPO is on. The signed file is kept on the submission. EPO answers with:
4. a potvrzení — kept under Receipts, and its podací číslo becomes the submission's Authority reference; the submission is Delivered;
5. for a large filing processed off-line, an ID předání — the submission is Delivered and the potvrzení is fetched later;
6. a list of errors — the submission Fails with EPO's messages, and a to-do activity is scheduled for the user who created the submission.
7. Acceptance. An hourly job asks EPO for the state of every delivered EPO filing until the tax office has accepted or rejected it, and sets the submission to Accepted or Rejected.
8. Once EPO has taken the filing, a statement still at Exported is marked submitted automatically — its filed copy is frozen — and the podací číslo is copied to its Submission reference.

Delivered means EPO received the filing; only Accepted means the tax office took it. The submission form says so while a filing is delivered.

What happens when something goes wrong

• EPO could not be reached (the connection was never established): the submission goes back to the queue and is retried after 1, 5, 15, 60 and 180 minutes, then fails.
• The outcome is unknown — the request may have reached EPO but no proper answer came back: the submission fails and is not retried, because sending it again could file the return twice. Check the filing on the MOJE daně portal before you send anything again. The same applies to any unexpected error, including one while recording EPO's potvrzení after it has filed: the submission fails with the podací číslo in the message and a warning not to send it again.
• The certificate has expired or is not yet valid: the module refuses to sign.

Limitations

• EPO's checks are a subset of the tax office's. A clean check is not a guarantee that the filing will be accepted; the module repeats that warning.
• The handling of the live service's answers is implemented from EPO's published interface description and has not been confirmed against the live service from this code base.
• The module checks the certificate's validity dates, not that it is a qualified certificate; EPO checks that.
• EPO returns no PDF of the filing.