The obligation arises directly from Article 82, section 1, point 2 of the Tax Ordinance, according to which taxpayers to meet this requirement have 3 months following the end of the tax year for which the information is drawn up. It should be emphasised, however, that on 1 January this year the new regulations entered into force, providing for certain exemptions in this respect for some taxpayers. Thanks to the amended regulations, entities which are obliged to prepare the transfer pricing information (TPR) and do not conclude transactions with entities from the so-called "tax havens" are simultaneously exempt from the obligation to file the ORD-U. Importantly, this exemption also applies to forms submitted for 2021.
It is important to note that entities wishing to benefit from the above exemption should verify their transactions with counterparties, indicated in the TPR form, in the context of "tax havens".
Please note that under existing legislation, the deadline for submitting transfer pricing information (TPR) for 2021 for taxpayers whose tax year coincides with the calendar year is the end of November 2022.