Booking commission and VAT are linked more closely than they look. A portal based abroad usually invoices its commission without Czech VAT, and the tax on it is yours to declare, not the portal's. A VAT payer (plátce DPH) declares it and deducts it at the same time, while a non-payer becomes an identified person (identifikovaná osoba) because of it and has to pay it.
How a direct booking on your own website looks in Chalupario
You tax a commission from abroad, not the portal
The commission is a service the portal provides to you. A service provided to a taxable person has its place of supply where the recipient has its seat (§ 9(1) of the VAT Act), which for you is Czechia. A taxable person is anyone who independently carries on an economic activity, and that includes using property to earn a regular income (§ 5(3)). Anyone who regularly lets a cottage for payment is therefore a taxable person, whether or not they are a VAT payer.
When the service is provided by a person not established in Czechia, the tax is declared by whoever received it, that is a payer or an identified person (§ 108(3)(a)). That is why the portal's invoice arrives without Czech tax and the duty to declare it stays with you.
Which month the tax belongs to is decided by the day the service is provided (§ 24(2)(b)). If you pay the commission earlier and it is already clear what it is for, the day of payment applies (§ 24(3)). Which day that is for your commission, check with your accountant against the portal's terms.
A non-payer becomes an identified person and has 15 days to register
A non-payer with a seat in Czechia is an identified person from the day it received a service from a foreign person, or from the day it paid for it, whichever comes first (§ 6h(a)). That does not make you a VAT payer. You become a payer only after turnover above CZK 2,000,000 in a year (§ 6(1)).
You file the registration application within 15 days of the day you became an identified person (§ 97), and only electronically (§ 101a(2)). The deadline runs once, from the first commission from any portal, not separately for Booking.com and Airbnb.
Booking commission and VAT for a non-payer: 21% of the commission, declared monthly
The tax period is the calendar month (§ 99). An identified person files the tax return electronically (§ 101(1)(b) and § 101a(1)). For a month in which no duty to declare tax arose, it files nothing and notifies nothing (§ 101(5)).
The deadline is 25 days after the end of the month and cannot be extended (§ 136(4) of the Tax Code). The tax is due on the last day of that deadline (§ 135(3) of the Tax Code).
The rate is the basic rate, 21% (§ 47(4)). Annex 2 to the VAT Act does list accommodation services at the reduced rate, but brokering accommodation is not in it. Only a payer can deduct input tax (§ 72(1)), so a non-payer really bears the tax on the commission.
Example: the portal charges you a commission of CZK 1,500 for the month. The base is that amount and the tax is 21%, so CZK 315. A commission in euros is converted at the rate for the day the duty to declare tax arose, using either the Czech National Bank rate or the European Central Bank reference rate (§ 4(8)).
An identified person keeps records for VAT (§ 100(1)), so keep the portal's invoice. You remain a non-payer, so never show tax on documents for guests. What belongs on such a document is covered in Accommodation invoice in Czechia: what it must contain and when.
A payer declares the commission and deducts the same tax
A payer declares the tax on the commission just as a non-payer does (§ 108(3)(a)), only in its regular return. It claims the deduction if it has declared the tax and holds a document (§ 73(1)(b)), and the right arises for a service used for taxable supplies with a place of supply in Czechia (§ 72(1)(a)).
Accommodation in Czechia is exactly such a supply, because the place of supply is where the property is (§ 10(1)). Output tax and deduction therefore usually cancel out and you pay nothing extra.
The commission still appears in the control statement (kontrolní hlášení), because you incurred a duty to declare tax on it under § 108(3) (§ 101c(b) point 1). A legal person files it within 25 days after the end of the month, an individual within the deadline for the tax return (§ 101e).
What to take away
- A commission from a foreign portal is a service with its place of supply with you, and you declare the tax on it (§ 9(1), § 108(3)).
- A non-payer becomes an identified person and files the application within 15 days (§ 6h, § 97).
- A non-payer declares 21% of the commission for every month it had one, within 25 days after the month ends, and has nothing to deduct it against.
- A payer declares the commission, deducts it and shows it in the control statement (§ 73(1)(b), § 101c(b)).
- On a document for a guest a non-payer shows no tax, even when it is an identified person.
What to do now
- Find the first commission invoice from Booking.com or Airbnb and note its date and amount.
- If you are a non-payer and not yet an identified person, file the electronic application within 15 days of the date from step one. If the deadline has passed, do not put it off and contact your accountant and the tax office.
- Record the commissions from all portals by month and file the return accordingly (non-payer), or include them in the return and the control statement (payer). Check your own case with your accountant first.
