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CZ VAT Status (plátce / identifikovaná osoba / neplátce)

Records when the Czech company was a VAT payer, an identified person or a non-payer, and taxes every invoice, bill, DPHDP3 and kontrolní hlášení by the status on the document's own date.

What it is for

A Czech company is not always a plátce DPH (VAT payer). It may start as a neplátce (non-payer), become a plátce when its turnover crosses the threshold or by voluntary registration, be an identifikovaná osoba (identified person, registered only for cross-border transactions) in between, and be deregistered again. Each change takes effect on a particular day, often mid-year.

Without this module the Czech localization treats every Czech company as a plátce. With it you record the company's status history, and every document is taxed by the status on its own date:

• a non-payer's invoices carry no VAT and are not presented as a daňový doklad; its suppliers' VAT becomes part of the cost;
• an identified person self-assesses VAT on intra-Community acquisitions and services from abroad, without a deduction, and keeps reporting its services to other member states;
• DPHDP3 is filed with the right typ plátce, and the kontrolní hlášení covers only the days the company was a plátce.

No history, no change. Until the company has at least one status row nothing behaves differently: DPHDP3 says P, taxes, the kontrolní hlášení and the invoice stay as they were, and no new taxes are created.

Legal background

All references are to the zákon o DPH (235/2004 Sb.).

• Who becomes a plátce. § 6 odst. 1: from 1 January of the year after the year in which the domestic turnover exceeded CZK 2,000,000; § 6 odst. 2: from the day after the turnover exceeded CZK 2,536,500 in the current year, or the day after the threshold was exceeded if the person chose so in a timely registration. § 6f: voluntary plátce from the day after the registration decision is notified. § 6g–6i: identifikovaná osoba from the day of the first acquisition, receipt or supply that triggers it.
• Ceasing. § 107b odst. 3 and 4: a plátce or identifikovaná osoba deregistered on request ceases on the day after the decision is notified; § 107b odst. 5: a plátce deregistered on request becomes an identifikovaná osoba on the day it ceases to be a plátce, if it does not meet the conditions for cancelling that registration too or asked for it.
• Output VAT. § 108 odst. 1: a plátce must declare VAT on its taxable supplies. § 108 odst. 4 písm. g): whoever issues a document stating VAT must declare it — which is why the module refuses to post a non-payer's invoice with VAT instead of merely warning.
• What an identifikovaná osoba owes. § 108 odst. 2: VAT on an intra-Community acquisition of goods (plátce or identifikovaná osoba); § 108 odst. 3 písm. a): VAT on a service, goods with installation or goods through networks supplied by a person not established in the Czech Republic. Other goods from such a person (§ 108 odst. 3 písm. b)), the domestic reverse charge (§ 108 odst. 4 písm. a)) and import self-assessment (písm. c)) name only a plátce; a non-payer pays import VAT to the customs office (§ 108 odst. 5 písm. a)).
• Deduction. § 72 odst. 1 gives the right to deduct to a plátce only; § 72 odst. 5: it arises when the obligation to declare the tax arose.
• Tax point. § 20a odst. 1: the obligation to declare VAT arises on the day of the taxable supply (DUZP).
• Filings. § 101 odst. 1: a plátce and an identifikovaná osoba file a VAT return; § 101c: "Plátce je povinen podat kontrolní hlášení" — a non-payer and an identifikovaná osoba file none.
• Documents. § 28 odst. 1: the duty to issue a daňový doklad is a plátce's; § 28 odst. 3 extends it to any osoba povinná k dani for a cross-border service.

Setting it up

Settings → Users & Companies → Companies, open the Czech company, tab VAT status (shown only for companies in the Czech Republic).

1. Add one row per change, oldest first. Each row says "from this day on, the company was …" and applies until the day before the next row. Days before the first row count as plátce, so if the company started as a neplátce, its first row must say so (legal basis Nikdy nebyl registrován, from its first day).
2. For each row choose the Legal basis and enter the Event date — the day the Act counts from (turnover exceeded, decision notified, decision final, first acquisition…). The status and the Valid from day are then proposed:

For a § 6 plátce the status arises by law on the day shown, whatever the date of the registration decision: enter that day, not the decision's. The proposal is only a proposal; Valid from stays editable. A legal basis that does not fit the chosen status is refused. 3. Optionally record the Č. j. rozhodnutí (reference of the tax office's decision) and a note.

VAT status today shows the current status. The two Invoice statement fields hold the sentence printed on a non-payer's and an identified person's invoices (defaults "Nejsem plátce DPH." and "Nejsem plátce DPH (identifikovaná osoba)."; a legal entity may prefer "Nejsme plátci DPH."; empty prints nothing).

As soon as a row with a non-payer status exists, the module creates the non-payer variants of the company's purchase taxes (see Taxes). Regenerate non-payer taxes creates any that are missing; it also runs on its own whenever the history changes and before posting.

Changing the history later re-decides documents already posted: their kontrolní hlášení section is recomputed from the earliest changed day, and VAT-deferral entries are withdrawn or created (see Filings). Returns already filed are not changed — correcting them takes a dodatečné přiznání.

Which date decides

A document takes the status on its DUZP (Taxable Supply Date), falling back to the invoice date and then the accounting date. Both questions the status answers — does output VAT arise, is input VAT deductible — are tied to the tax point by § 20a odst. 1 and § 72 odst. 5; the issue date and the accounting date decide neither.

• Boundary days. A row applies from its first day inclusive. A document whose DUZP is the first day of a new status falls under the new status; one dated the day before, under the old one.
• Credit notes take the status of the invoice they correct, even when issued after the change.
• On a non-plátce date the document shows Company VAT status next to the DUZP.

What happens to taxes

Taxes are recognised by the DPHDP3 row their base is reported on (the VAT Base tags of the Czech chart), so taxes you add yourself are handled the same way as long as they carry the chart's tags.

The variants are copies of the source tax, named after it with the suffix (no deduction) or (identified person), and linked to it (field Plátce tax on the tax form):

• No deduction — a single tax line with no account and no tags. Odoo posts it onto the expense account of the bill line, so the VAT becomes part of the cost; nothing reaches account 343 or the return.
• Self-assessed, no deduction — the liability side and its output tags (ř. 3–6, 12, 13) stay as on the plátce tax; the deduction side loses its account and lands on the cost, and every deduction tag (ř. 40–53) is removed. DPHDP3 shows the output tax and no deduction.

Taxes are applied automatically when lines are created from a product or account, and again when you change the DUZP or invoice date of a draft across a status boundary — in both directions, so moving the date back restores the plátce taxes.

Posting is refused when an invoice's taxes do not fit the status on its DUZP. A draft with such lines shows a warning with the button Apply VAT status taxes, which replaces them. A purchase tax whose repartition does not have the shape of the Czech chart (one +100 % and one −100 % tax line) gets no identified-person variant; a bill using it on an identified-person date cannot be posted until you set the tax by hand.

On the invoice

A customer invoice dated while the company is not a plátce:

• carries no VAT (the taxes were removed);
• does not print the DUZP — the one element that exists only because of VAT. Odoo's title "Invoice" (Faktura) claims nothing and is left as it is;
• prints the Invoice statement below the notes.

The exception is an identified person's § 9 odst. 1 service to another member state, which § 28 odst. 3 requires to be documented by a daňový doklad: such an invoice keeps its DUZP. The identified-person statement is printed on it too.

Filings

• DPHDP3. typ plátce is taken from the status on the last day of the return's period: P plátce, I identifikovaná osoba, N neplátce. Each document in the period was taxed by the status on its own DUZP. When the status changes within the period, the return says so in its chatter when computed; whether the change needs a separate filing for part of the period is for you and the tax office to decide.
• Kontrolní hlášení. Only documents dated on plátce days are included. A period with no plátce day cannot be computed at all; the message tells you to answer a tax-office request (výzva) with "B – Nemám povinnost podat KH". A period with a change is computed from the plátce days, and the statement's chatter lists the segments.
• Souhrnné hlášení. An identified person's § 9 odst. 1 services keep their tax, so the EC sales list reports them as for a plátce.
• VAT period declared (the later deduction period from l10n_cssk_core). It exists for a plátce who claims a deduction later than it arose. On a document dated while the company was not a plátce it is ignored: the document is reported in the period of its tax point, and its VAT is not moved off account 343 by deferral entries. The form says so in a blue note. If a history change should withdraw or create deferral entries in a locked period, the document gets a chatter message and the entries are left for you to correct.

Sales and purchase orders

Two bridge modules install themselves when Sales or Purchase is installed:

• l10n_cz_vat_status_sale — sales order lines;
• l10n_cz_vat_status_purchase — purchase order lines, including lines created by reordering rules and make-to-order.

They propose the taxes the status allows on the order date. An order has no tax point, so this is only a proposal: the invoice or bill made from it is decided again by its own DUZP and cannot be posted with taxes that no longer fit. An order confirmed in June and invoiced in July across a registration gets its taxes corrected on the invoice.

Limitations

• Adjustments on a status change are not made: the deduction of VAT on stock and assets when becoming a plátce, and the corrections and payments due on deregistration. Book them by hand.
• The turnover threshold is not monitored. The status is what you record.
• Skupina (group registration, typ plátce S) and nový dopravní prostředek (R, D) are not modelled; ř. 9 taxes are left alone.
• Import VAT paid to customs by a non-payer is not booked: the import taxes are removed from the bill, and the VAT the customs office assesses is booked from the customs document as a cost.
• Advance invoices made by other modules are not stopped; a non-payer should not issue them.
• OSS and the EU small-business scheme are not statuses of this module.
• Imports of historical documents can skip the posting check with the technical context key l10n_cz_vat_status_skip_check; nothing in the user interface sets it.
• Open questions for your tax adviser, where the module takes a default: ř. 12/13 taxes are treated as owed by an identified person, although they also cover § 108 odst. 3 písm. b) goods, which only a plátce owes; an intra-Community acquisition is decided by the DUZP on the bill, not by the § 25 tax point; a credit note after deregistration takes the status of the original invoice; a plátce's own self-assessment with a later declared period still moves the liability together with the deduction.