Corrective, Follow-up, and Zero Control Reports

Quick Overview: Corrective vs. Follow-up vs. Zero Control Reports

The difference between a corrective and a subsequent report is primarily determined by when you discover the error. A corrective tax return replaces a previously filed return before the regular filing deadline has passed. A subsequent tax return is used to correct an error after the deadline has passed and must be filed within 5 business days of discovering incorrect or incomplete information.

Not sure whether to correct the error with a corrective or a follow-up tax return? If the incorrect filing could affect your tax liability or if you’ve already received a notice from the tax office, we’ll help you choose the right course of action and review any follow-up filings.

What Is a VAT Control Report and Who Files It

The control report is governed by the Value-Added Tax Act, specifically its provisions regarding control reports. This means it is a separate tax return that does not replace the VAT return or the summary report, but supplements them with detailed data from tax documents—particularly regarding the relationships between specific suppliers and customers.

It is filed exclusively electronically in a precisely defined format (XML), and its purpose is to verify the consistency of documents between business partners and to detect tax fraud (such as carousel schemes).

Who Must File the Control Report

In general, control reports are filed by VAT payers registered in the Czech Republic, including both Czech and foreign entities registered as VAT payers. For a group of VAT payers, a representative member files the report on behalf of the entire group.

The obligation to file a report arises if, during the so-called reporting period (month or quarter), at least one of the typical situations occurs, such as:

• you make a taxable supply within the country (typically a VAT invoice to your customer),
• you receive a supply for which you report output tax under the reverse charge mechanism,
• you claim an inputtax deduction on received supplies,
• you make specific supplies under the special regime for investment gold.

In other words—if your VAT return is blank for a given period, this likely means you are not filing a control report either (we’ll explain the exceptions below under “zero control reports”).

When Do I Not Need to File a Control Report?

The following do not need to file a control report:

• a person who is not a VAT payer,
• an identified person. That is, someone who was required to register for VAT solely due to cross-border transactions (typically the purchase of goods or services from the EU) but is not a regular VAT payer.
• a taxpayer who, during the reporting period, neither made nor received any transactions that must be reported on the control statement (e.g., no taxable transactions, no right to a tax credit),
• a taxpayer who carries out only tax-exempt transactions without the right to a deduction (typically certain financial, insurance, and healthcare services, etc.).

Deadlines and Types of Control Reports: Regular, Corrective, and Follow-up

Control reports must be filed by clearly defined deadlines. Legal entities must file control reports monthly, regardless of whether they have a monthly or quarterly VAT reporting period. The filing deadline is the 25th day following the end of the calendar month.

For individuals who are VAT payers, the situation is different. They file control reports with the same frequency as their VAT returns, i.e., either monthly or quarterly. However, the same rule applies here: the control report must be filed no later than the 25th day following the end of the relevant tax period. In other words, if you are a quarterly filer—an individual—you file a control report four times a year, always by the 25th day following the end of the given quarter.

In terms of content and purpose, we distinguish between three basic types of control reports. The regular control report is the first one you file for a specific period and serves as the basis for any subsequent corrections. If you discover an error before the filing deadline has passed, you file a corrective control report, which fully replaces the original report. However, if you discover the error after the deadline has passed, you must file a subsequent control report to correct the data retroactively.

Regular Tax Return—the Foundation on Which Everything Depends

A proper control report is the first and primary control report for a given period, to which all subsequent corrective and follow-up filings relate. You can think of it as the initial version —with this filing, you first inform the tax authorities of the taxable transactions you made and received during the given month or quarter.

When preparing a control report for a specific period, you always start with the regular report. In it, you include all the information required by the VAT Act: primarily specific invoices, customers and suppliers, their VAT ID numbers, tax bases, VAT rates, and tax amounts. In the individual sections of the form, you detail your transactions with your business partners—who invoiced whom for what, in what amount, and with what tax. A proper control report is therefore not just a summary figure, but a detailed list of transactions that the tax authority subsequently cross-checks with the other party’s (supplier’s or customer’s) data.

Timing is also important. The regular control report must be filed by the 25th day following the end of the month or quarter, depending on whether you are a monthly or quarterly taxpayer. In practice, this often works as follows: first, you prepare your VAT return, and then, based on the same documents, you immediately compile the proper control report. The order in which you submit these two forms does not matter—what’s important is that their content matches and that both are submitted on time.

Since the regular control report is what gives the tax authorities their first overview of your transactions, it’s worth paying close attention to it. If you prepare the regular report carefully and verify its consistency with the VAT return, it will save you a lot of trouble—from subsequent requests for clarification due to discrepancies to the need to file corrective or follow-up reports.

It’s also important to realize that any subsequent correction is based on the regular report. When you file a corrected control report, you’re essentially saying, “I’m withdrawing the original regular report and replacing it with this new version.” When you file a subsequent control report, you are again basing it on the original data from the correct report and replacing it with a correction filed after the deadline has passed.

Corrected Tax Return—When to File It and How to Correct an Error in Time

A corrective tax return is your safety net when you realize in time that the original tax return contains an error. Typically, this is a situation where you have already submitted the return, but the deadline for filing has not yet passed —that is, the 25th day after the end of the relevant period has not yet arrived. In this case, you simply replace the original regular return with a corrected tax return, which is then taken into account, while the original version is no longer considered valid.

The simple answer to the question of when to file a corrected tax return is: whenever you have already submitted the original return but the regular filing deadline has not yet passed.

As soon as you realize that the regular tax return is incorrect, you do not need to provide the tax office with any special explanation. Simply file a new, amended tax return with the correct information. Keep in mind, however, that you must complete the entire amended tax return from scratch. This means that you transfer all the originally correct information to the form and only correct or add the information that was incorrect. The tax authority then treats the corrected control report as the only valid version; the original control report is effectively removed from consideration.

It also often happens that the same error carries over into the VAT return —for example, a missing invoice will affect both the control statement and the total of the tax base and VAT in the return. In such a case, it is advisable to also file a corrected VAT return for the same period at the same time, again within the regular filing deadline. It is important to distinguish here: if you are still within the deadline, you file a corrected return, not a supplementary one. A supplementary return is only required once the filing deadline has passed.

Tip: The difference between a corrective and a follow-up report lies not in the type of error, but primarily in when the error is discovered. As long as the regular deadline has not passed, you resolve the error by filing a corrective tax return. Once that deadline has passed, you must file a follow-up tax return.

Subsequent Tax Return – When You Discover an Error Later

A subsequent tax return comes into play when you realize that the tax return for a specific period is incorrect, but you don’t discover this until after the regular filing deadline has passed. In this case, you can no longer file a corrected return because the regular filing deadline has passed, but you are required to file a subsequent tax return.

You have only 5 business days from the moment you discover the error to file the subsequent tax return. The deadline, therefore, is not based on the end of the month or the date you originally filed the return, but on the moment the error was discovered.

Again, the subsequent control report is not filed merely as a summary of differences, but as a new, complete version of the control report for the given period. This means that you must re-enter all the originally correct data and, at the same time, correct or supplement the incorrect information. The tax office then treats this subsequent return as the current version. You thus replace the original correct return (or any previously filed amended return) with this new filing.

When an error in the control report also means that the VAT return is incorrect, it is often necessary to file an amended VAT return for the same period as well. An amended return is used precisely when the tax liability changes after the filing deadline has passed.

It is especially important not to delay when filing a subsequent report. As soon as you discover the error, don’t wait—start working on the correction immediately. This is partly due to the strict five-day deadline and partly because any delay may result in notices from the tax office and, subsequently, penalties.

Correcting Errors in the Control Report: What to Do in Different Situations

Now let’s summarize the typical scenarios we encounter in practice.

You discover the error before the 25th

For example, you filed a regular control report for April, but on May 20, you discover that one issued invoice is missing from it.

Procedure: File a corrected control report for April. In the report, re-enter all the data, but this time including the corrected invoice. If the error also affected your VAT return, file a corrected VAT return.

If you complete everything within the deadline, the control report is not considered late, and therefore you will not incur a penalty for late filing.

You discover the error after the 25th—but on your own, without being prompted

For example, you filed the regular control report for April on May 20, but on June 5, while reviewing your accounting records, you discover that one invoice received under the reverse-charge mechanism is missing.

Procedure: Starting June 5, you have 5 business days to file a subsequent control report. You will therefore file a subsequent (complete) report for April. If the reported tax amount also changes, you must file an amended VAT return.

If you filed the original report on time and are now merely correcting an error, a penalty generally does not apply—provided, of course, that you do not exceed the statutory deadlines for the subsequent report or are not subsequently penalized for failing to comply with a request.

From a lawyer’s perspective: A common mistake is not the incorrect invoice itself, but the fact that the business owner corrects only the control report and forgets to check whether the same error also affected the VAT return. When making a correction, we therefore recommend always comparing both forms and verifying that the change does not also affect the tax liability itself.

Late Filing of the Control Report—When You Forget Entirely

This is the situation that business owners dread the most. For example, you are a VAT payer and fail to file either your VAT return or your control statement for April. The 25th day after the end of the month passes, and the report still hasn’t been filed.

At this point, you’ll incur a fine of 1,000 CZK for late filing of the control report if you file the report yourself retroactively, without being prompted by the tax office. However, if this is the first such fine in the given calendar year, it is automatically waived (provided you corrected the error on your own without being asked).

Even so, the rule remains: the sooner you notice and correct the errors, the better—both for the sake of clarity and to avoid the risk of further requests and penalties.

What to Check Before Correcting a Control Report

Before submitting a new filing, verify:

• the period for which you are correcting the error,
• whether the regular filing deadline is still open or has already passed,
• which specific documents or data are incorrect,
• whether the error also affects your VAT return,
• whether the tax office has already sent you a notice,
• and, if applicable, the start date of the response period.

Correcting an error in the control report may also require you to correct the VAT return itself. Therefore, always review both forms together.

Responding to a Request Regarding the Control Report

A notice from the tax office regarding the control report is issued when the tax administrator determines that you have not filed a control report at all, or that the filed report does not match the data provided by your business partners, or if the tax administrator has doubts about the accuracy or completeness of the reported data. In such a case, the tax office will send you a request specifying the period for which the control report must be submitted, whether you are required to file a regular control report or a subsequent control report, and the specific deadline by which you must respond.

If the request is delivered to your data box, you have 17 calendar days to respond from the time it was delivered to the data box. If you receive the request by other means, such as by mail, the deadline is 5 business days from the date of delivery or notification of the request. It is essential that you respond to such a request exclusively by filing a tax return —simply sending an explanatory letter, a brief statement, or an email is not sufficient.

Have you received a request from the tax office and are unsure whether to change, supplement, or simply confirm the information? The response deadlines are short, and an incorrect response can have financial consequences. Contact us! We can help you assess the request and prepare the correct response.

Penalty for Late Filing of a Tax Return

It’s definitely not worth ignoring a notice from the tax office. If you fail to meet the response deadline, relatively strict penalties will apply. If you submit the audit report only after the extended deadline following the notice, you face a fine of 10,000 CZK. If you fail to file a follow-up tax return within the specified deadline in response to a request to resolve discrepancies, the tax office may impose a fine of 30,000 CZK. And if you fail to file the control report even within the extended deadline set by the tax administrator, you face a fine of 50,000 CZK.

However, the tax authority’s options do not end there. Beyond these automatic penalties, the tax administrator may impose a fine of up to 50,000 CZK if you fail to respond at all to a request to resolve discrepancies, or if you respond in a manner that does not comply with the requirements of the law —typically by failing to file the required subsequent control report.

Starting in 2023, fines of 10,000, 30,000, and 50,000 CZK for selected taxpayers —such as individuals, quarterly taxpayers, or certain single-member limited liability companies— will be reduced by half.

In the most serious cases, where the tax authority deems your actions to constitute a serious obstruction or hindrance to tax administration, the fine can reach up to 500,000 CZK. That’s why there’s a simple rule: as soon as a request for a control report arrives in your data box, treat it as a priority and address it without delay.

Zero Control Report: When to File It and When Not to

The term “zero control report” is used in two different situations, which often leads to confusion.

1. Situations in which no control report is filed at all

You do not file a control report if:

• you are not a VAT payer,
• you are only an identified person,
• as a taxpayer, you did not make or receive any transactions in the given period that would need to be reported,
• you only perform transactions that are exempt without the right to a tax credit.

2. Actual Zero Control Report—When You File One, but It Contains Only Zeros

In practice, a “zero control report” primarily refers to a response to a request from the tax office in a situation where you are convinced that you had no obligation to file a control report for the given period.

In such a case, on the control report form, select the“Quick Response to Request” option and choose “I am not required to file a control report (KH).” Fill in the required information in the header, the taxpayer’s identification, and the reference number of the request you received. This is therefore not simply a standard control report in which you would fill in nothing but zeros.

From the perspective of the Tax Administration, you are clearly declaring that you were not required to file a control report for the given period, while at the same time properly responding to the tax authority’s request.

Summary