EET 2.0 in practice: self-service premises, cancellations and foreign-currency payments

Sales of goods or services through vending machines are to be excluded from reporting. A vending machine is a self-service technical device that requires customer involvement only to the extent necessary to order or receive the goods or service. One example is a coffee machine that prepares and dispenses the final product after the customer places an order. By contrast, self-service petrol stations and self-service grocery stores do not qualify for this exemption because customers actively participate in the purchase process. Payments made at these premises should therefore be subject to electronic sales reporting.

Sales received in a foreign currency are converted into Czech crowns using the exchange rate normally applied by the business at the time of the sale, e.g., in its point-of-sale or accounting system. If the business does not use its own exchange rate, it may choose another appropriate rate, such as the Czech National Bank exchange rate. The amount actually received must always be reported. A cash payment rounded to whole crowns is therefore reported at the rounded amount, whereas a card payment including halers is reported at the exact amount paid, i.e. to two decimal places in Czech crowns.

A specific approach applies to fleet cards used to purchase fuel. Transactions made using these cards will not be subject to reporting because their use generally does not involve a payment at that point: it merely records the amount that will be subsequently invoiced to the customer. The reporting obligation therefore applies when the invoice is subsequently paid.

The financial administration has also clarified the procedure for correcting and cancelling individual sales. When correcting an incorrectly reported sale, returning goods or cancelling a transaction, the relevant amount shall be reported as a negative amount. The correction message will not be technically linked to the original sale and will have its own sequential number, date and time. It should be submitted when the circumstances justifying the correction or cancellation arise.

The financial administration’s answers also revisit the definition of an in-person payment: if a customer pays a business directly at the place where a service is provided (e.g., for a plumber’s services) by cash, card or QR code, the payment should qualify as an in-person payment subject to reporting. If the business merely issues an invoice which the customer subsequently pays remotely, no reporting obligation should arise. This distinction is consistent with the principles previously described by the financial administration, e.g., in relation to e-shops and payments made upon delivery of goods.

By contrast, the bill does not provide an option to request a binding ruling from the tax authority on whether a particular payment is subject to reporting. Businesses with doubts should contact the financial administration’s helpline.

The above answers are based on the current wording of the bill. However, the Senate has returned it to the Chamber of Deputies with, among other proposals, an amendment to exclude non-cash payments from reporting. Such a change would fundamentally affect the overall concept of EET 2.0, which is based on reporting in-person payments irrespective of their form. It therefore appears more likely that the Chamber of Deputies will override the Senate on this point and retain the original scope of reportable payments.