Ganado

INVOICING ABROAD

Invoicing foreign clients from the Czech Republic: VAT, IO and FX

Invoicing a foreign client and unsure when identified-person status kicks in, whether VAT belongs on the invoice, or which exchange rate to use? Here is the Czech side in one place — place of supply, reverse charge, identified-person status, the EC Sales List, ČNB exchange rates, and a worked invoice with visible arithmetic.

Describe my invoicing IT contractor taxes guide
  • A B2B service to a taxable person in another EU state has its place of supply at the customer's seat, not in Czechia (§ 9(1) of Act No. 235/2004 Coll.) — the invoice carries no Czech VAT.
  • That invoice must state that the customer accounts for the tax — a mandatory element of a reverse-charge document under § 29(2)(c) of Act No. 235/2004 Coll., not optional wording.
  • An OSVČ who is not yet a VAT payer becomes an identified person from that first invoice — regardless of the amount, because the law sets no turnover threshold for this type of supply (§ 6i of Act No. 235/2004 Coll.). Registration is due within 15 days.
  • An EC Sales List (souhrnné hlášení) must also be filed for every month with such a supply, within 25 days of the month's end (§ 102(3) and (5) of Act No. 235/2004 Coll.) — a separate duty from the annual tax return.
  • Convert EUR amounts using the ČNB rate valid on the day of the actual supply, or a fixed rate chosen at the start of the period — both are allowed.

Responsibility for this page rests with Ganado International s.r.o., company ID 19322119 (ARES registry entry), acting through its director Artem Chagin. It is general information as of the update date, not tax advice on your specific case.

Place of supply and reverse charge

Place of supply decides whether Czech VAT belongs on the invoice — not where you physically work from. For an ordinary B2B service (software development, consulting, marketing, infrastructure work) supplied to a taxable person in another EU state, the place of supply is the customer's seat, not Czechia (§ 9(1) of Act No. 235/2004 Coll.). The invoice is issued with no Czech VAT.

That invoice must state that the customer accounts for the tax (reverse charge) — this is a mandatory element of a reverse-charge document under § 29(2)(c) of the same Act, not merely a recommended phrase. Without it the invoice is formally incomplete, even though it correctly carries no VAT.

For a B2C service (a non-business customer), the general rule keeps the place of supply at the supplier's seat — i.e. Czechia — with exceptions for electronically supplied and certain other services, where a special regime (e.g. OSS) applies instead. If you invoice ordinary consumers abroad, check the service type separately — the B2B rule above does not carry over to B2C automatically.

Who are you invoicing? What applies

Two things decide the answer: where the customer is established, and whether it is a taxable business (B2B) or an end consumer (B2C).

Situation What applies
A B2B service to a taxable person in another EU state Place of supply at the customer's seat (§ 9(1)). Invoice with no VAT, stating that the customer accounts for the tax. Identified-person status starts from the first such invoice, and an EC Sales List is due for that month.
A B2C service to a consumer in another EU state (an ordinary service, not electronic) The place of supply generally stays at the supplier's seat, i.e. Czechia. You invoice with Czech VAT if you are a VAT payer, or without VAT if you are not and the supply does not trigger identified-person status.
A B2B or B2C service to a client outside the EU For B2B, the place of supply is also at the customer's seat outside Czechia, but identified-person status under § 6i and the EC Sales List apply specifically to supplies into another EU member state — they do not apply here. Invoicing without VAT still holds; the reverse-charge wording is not required for a non-EU client, but check that country's own rules.
Buying a service from a foreign platform (Google Ads, AWS, Meta) — a received, not supplied, service This is a supply received from a person not established in Czechia — identified-person status arises under § 6h from the first such supply, with no threshold and regardless of whether you invoice abroad yourself.
An electronically supplied service (SaaS, a digital product) to an EU end consumer The place of supply is at the customer's seat despite being B2C — handled under the One Stop Shop (OSS) special regime, not the ordinary B2B process described above.

The table covers the most common scenarios for an OSVČ invoicing abroad. The combination of service type and customer location always decides case by case — check an unclear case in advance.

Identified-person status and the EC Sales List

Identified-person status and VAT-payer status are two different regimes with different triggers. You become a full VAT payer on domestic turnover — after exceeding CZK 2,000,000 from the first day of the following calendar year, and after exceeding CZK 2,536,500 from the very next day (§ 6(1) and (2) of Act No. 235/2004 Coll.). Domestic turnover is only "the sum of consideration excluding tax ... for supplies with a place of supply in Czechia" (§ 4a(1) of the same Act), so revenue with a place of supply abroad does not count toward it — which is why a contractor invoicing exclusively abroad can remain an identified person for years without ever becoming a VAT payer.

Under § 6i of Act No. 235/2004 Coll. you become an identified person "from the day of supplying a service with a place of supply in another Member State under § 9(1)", or from the day you received payment for that service in advance if the service is already known with sufficient certainty — whichever comes first. So a deposit received before delivery can trigger the status earlier than the invoice does. Registration is then due within 15 days of that day.

You also become an identified person from the other direction, on supplies you receive: "from the day of receiving a taxable supply with a place of supply in Czechia from a person not established in Czechia" (§ 6h of the same Act). That covers a contractor's typical purchases — Google Ads, Meta, AWS, foreign SaaS licences — and here too the law sets no threshold: the first such supply decides.

A third trigger concerns goods rather than services: you become an identified person "from the day of the first acquisition of goods from another Member State" (§ 6g of the same Act), but only for an acquisition that is subject to Czech tax — which starts above CZK 326,000 of goods acquired in the current or preceding calendar year (§ 2a(2) of the same Act). So buying hardware from the EU means watching the CZK 326,000 threshold, while services and invoicing into the EU have no threshold at all. The two figures — CZK 2,000,000 for VAT-payer status and CZK 326,000 for acquiring goods from the EU — belong to different duties and must not be confused.

The EC Sales List is filed for every calendar month in which such a supply occurred, within 25 days of that month's end (§ 102(3) and (5) of the same Act), and "exclusively in electronic form" (Czech Financial Administration) — separate from the annual tax return, which follows different rules and deadlines.

Worked example: first invoice to a German client

A sole trader (OSVČ), not yet a VAT payer, develops software for a company established in Germany and issues a first invoice for 5,000 EUR for a month of work.

Invoiced amount EUR 5,000
ČNB rate on the day of supply (18 Sep 2026) CZK 24.340/EUR
Converted amount for the records CZK 121,700
VAT on the invoice CZK 0 — reverse charge, stating that the customer accounts for the tax
Identified-person status starts on the day the service is supplied, regardless of the amount
Deadline for identified-person registration within 15 days of the supply
Deadline for the month's EC Sales List within 25 days of the month's end

CZK 24.340/EUR is the ČNB rate published for 18 September 2026 — illustrative, not current. For your own invoice, always use the rate valid on the day of the actual supply, or a fixed rate chosen at the start of the period.

Converting EUR invoices and ČNB rates

For bookkeeping purposes, assets and liabilities in a foreign currency are converted to CZK using the foreign-exchange market rate published by ČNB, as of the moment the accounting (tax) event occurs (§ 24 of Act No. 563/1991 Coll., on Accounting) — the same rule that underlies the practice for an OSVČ keeping tax records (daňová evidence) rather than full accounting.

You can choose between two methods: the current daily ČNB rate on the day of the actual supply, or a fixed rate — the ČNB rate on the first day of the period for which the fixed rate is used, unchanged for that whole period. You pick a method and keep it consistent; you do not mix them within one accounting period.

For income-tax return purposes, an OSVČ not keeping full accounting may instead use a single unified rate — the average of the ČNB rates published on the last day of each month of the tax period (§ 38 of Act No. 586/1992 Coll.). Current ČNB rates are published on the ČNB exchange-rate list.

What to send your accountant

Five details are enough for a first assessment of new foreign invoicing — with them we can confirm whether and from when identified-person status applies, and set up invoicing correctly from the first invoice.

  • The client's country and whether it is a business (B2B) or a private individual (B2C).
  • The type of service supplied (software development, consulting, an electronically supplied service, etc.) — this decides the place of supply for B2C.
  • The date of the first invoice or the planned start of the engagement.
  • Your current registration status (OSVČ with no VAT registration / identified person / VAT payer).
  • The invoicing currency and whether you will use the current daily ČNB rate or a fixed rate for the whole period.

What you send, what we do, when it is done

No introductory call. You describe the scope in writing and get a price and timeline back in writing.

  1. Send five facts

    Client country and type (EU business / non-EU / platform), approximate monthly income, current status (new OSVČ / taking over an existing one), whether and where you plan to physically work abroad, invoices per month.

  2. Get scope and price

    Within one working day we confirm whether and when identified-person status arises, which expense regime makes sense, and send a fixed price and invoice.

  3. We start after payment

    We handle registration where needed, set up your invoicing, and run ongoing records, EC Sales Lists and the annual return within the agreed scope.

Written reply within 1 working day.

What is billed separately

Monthly OSVČ bookkeeping starts at 990 CZK and covers ongoing records. The following are one-off or event-driven and billed separately at the published rates, so you can work out the total without a phone call.

Identified-person / VAT registration from 1,990 CZK Application, power of attorney and correspondence with the tax office when identified-person or VAT-payer status arises.
Monthly VAT / identified-person filing from 690 CZK / filing Preparing and filing for the month in which a relevant supply occurred.
Historical backlog cleanup from 1,990 CZK Reviewing and completing periods that were not correctly recorded or filed.
Standalone annual return outside continuous service from 2,990 CZK For contractors who want only the annual work, without monthly bookkeeping.

The annual return and the relevant insurance overviews are included in continuous monthly bookkeeping; they are billed separately only outside that scope.

VERIFIED

Verified

Primary sources for the place of supply, identified-person status, the EC Sales List and exchange rates described above.

  1. Act No. 235/2004 Coll., on VAT — § 2a, § 4a, § 6, § 6g, § 6h, § 6i, § 9, § 29, § 102
  2. Act No. 563/1991 Coll., on Accounting — § 24 (foreign currency conversion)
  3. Act No. 586/1992 Coll., on Income Tax — § 38 (unified rate)
  4. Czech Financial Administration — filing the EC Sales List
  5. ČNB — foreign exchange market rates

Send your situation, get a written reply

Client country, service type and the approximate date of the first invoice is enough for a first written reply.

FAQ Frequently asked questions
01 Do I become an identified person from the very first foreign invoice?
Yes, for a B2B service with place of supply at the customer's seat in another EU state — the law sets no turnover threshold here (§ 6i of Act No. 235/2004 Coll.). For a client outside the EU, identified-person status under this provision does not apply.
02 Does a VAT-free invoice need specific wording?
Yes — a statement that the customer accounts for the tax (reverse charge). This is a mandatory element of a reverse-charge document under § 29(2)(c) of Act No. 235/2004 Coll., not just a recommended sentence.
03 Does foreign revenue count toward the VAT-payer turnover threshold?
No, if its place of supply is outside Czechia. The turnover for § 6 consists only of supplies with a place of supply in Czechia (§ 4a). A contractor invoicing exclusively abroad can therefore stay an identified person long-term without ever becoming a VAT payer.
04 What is the EC Sales List and when do I file it?
A summary of services supplied with place of supply in another EU state, filed by both identified persons and VAT payers for every month in which such a supply occurred, within 25 days of that month's end (§ 102 of Act No. 235/2004 Coll.). It is a separate duty from a VAT return.
05 Which exchange rate should I use to convert a EUR invoice for my records?
Either the current daily ČNB rate on the day of the actual supply, or a fixed rate chosen at the start of the period (the ČNB rate on that period's first day). You choose a method and keep it consistent for the whole accounting period.
06 Do I file an EC Sales List for a month with no EU invoicing?
No — it is filed only for calendar months in which a relevant supply actually occurred.
07 Do the same rules apply to buying a service from a foreign platform (Google Ads, AWS)?
That is the mirror case — a received, not supplied, service. Identified-person status arises the same way from that first payment, regardless of whether you invoice abroad yourself.
08 Do the rules differ between an EU client and a non-EU client?
The place of supply for a B2B service is at the customer's seat in both cases. The difference is that identified-person status under § 6i and the EC Sales List apply specifically to supplies into another EU member state — they do not apply to a non-EU client.
09 What if I receive a deposit before the service is delivered?
Then identified-person status can arise on the day the payment is received. § 6i of Act No. 235/2004 Coll. ties the trigger to the day the service is supplied, or to the day payment for that service is received before it is supplied if the service is already known with sufficient certainty — whichever comes first. The 15-day registration deadline runs from that day.
10 Can I file the EC Sales List on paper?
No. It is filed "exclusively in electronic form" (Czech Financial Administration), typically via a data message or the MOJE daně portal, within 25 days of the end of the month in which the supply occurred.
11 Does the CZK 326,000 identified-person threshold apply to me?
That threshold applies to acquiring goods from another Member State, not services. An EU goods acquisition becomes subject to Czech tax only above CZK 326,000 in the current or preceding calendar year (§ 2a(2) of Act No. 235/2004 Coll.), and only such an acquisition triggers identified-person status under § 6g. For services supplied into the EU (§ 6i) or received from abroad (§ 6h) there is no threshold at all — the first supply decides.
12 Do I lose paušální daň because of foreign invoicing?
No. Identified-person registration is explicitly excluded from the conditions of the paušální daň regime (§ 2a(1)(a)(3) of Act No. 586/1992 Coll.) — see the flat tax for contractors guide for the details.

NEXT

Related services and guides

01

IT contractor taxes in the Czech Republic

The full picture: OSVČ setup, identified-person status, flat-rate expenses vs paušální daň, and švarcsystém at a glance.

02

Flat tax for contractors

When paušální daň pays off for a contractor invoicing CZK 100,000-200,000 a month, with two worked comparisons.

03

Švarcsystém — signs and risks

The statutory definition, the signs labour inspectors assess, and fines under § 139 and § 140.

04

Identified person

When the status arises, what is filed each month, and how the registration is handled.

CONTACT

Want your foreign invoicing set up correctly from the first invoice?

Send the client's country, the service type and your approximate income. We will tell you whether and from when identified-person status applies, which rate to use, and send a fixed price for bookkeeping.

Describe my invoicing