Subdivision 815-E of the Income Tax Assessment Act 1997 in Australia relates to reporting obligations for significant global entities regarding transfer pricing documentation and country-by-country reporting.

Key aspects of Subdivision 815-E include:

1. It applies to significant global entities, which are entities with annual global income of over AUD 1 billion.
2. These entities are required to provide three statements to the Commissioner of Taxation:
   • Country-by-country report
   • Master file
   • Local file
3. The statements must be provided in the approved form and relate to a specific income year.
4. The purpose is to implement measures issued by the Organisation for Economic Cooperation and Development (OECD) relating to transfer pricing documentation and country-by-country reporting, including Action 13 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Action Plan.
5. While not explicitly part of Subdivision 815-E, it’s worth noting that Subdivision 284-E of Schedule 1 to the Tax Administration Act 1953 sets out transfer pricing documentation requirements for penalty mitigation purposes.
6. The reporting obligations under Subdivision 815-E are mandatory for eligible entities, unlike the general transfer pricing documentation rules which are voluntary but can help establish a Reasonably Arguable Position (RAP) to mitigate potential penalties.

Subdivision 815-E works in conjunction with other transfer pricing rules in Australian tax law, such as Subdivisions 815-B and 815-C, which deal with arm’s length principles in cross-border transactions and permanent establishment profit attribution, respectively.