Law Companion Ruling

LCR 2015/3W

Subdivision 815-E of the Income Tax Assessment Act 1997: Country-by-Country reporting

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Notice of Withdrawal

Law Companion Ruling LCR 2015/3 is withdrawn with effect from 19 December 2025.

1. LCR 2015/3 discusses the implementation of the country-by-country (CBC) reporting measure as introduced by Schedule 4 of the Tax Laws Amendment (Combating Multinational Tax Avoidance) Act 2015, which inserted Subdivision 815-E into the Income Tax Assessment Act 1997.

2. The significant global entity (SGE) concept was expanded by the Treasury Laws Amendment (2020 Measures No. 1) Act 2020 so that, for income years or periods commencing on or after 1 July 2019, the concept also applies to certain 'notional listed company groups' that do not necessarily prepare global financial statements. It ensures that SGE-dependent tax laws pertaining to diverted profits tax and administrative penalties apply more broadly to better achieve their intended purpose.

3. Further, the law was amended so that CBC reporting lodgment obligations now turn on whether an entity is a 'country-by-country reporting entity' which constitutes a subset of the expanded SGE population. This change ensures that CBC reporting obligations are better aligned with Australia's international commitments.

4. LCR 2015/3 has been superseded by ATO website guidance including: Significant global entities (QC 51607), Country-by-country reporting entities (QC 64479) and Country-by-country reporting guidance (QC 54484). Detailed information on the local file is also published annually, as most recently represented by Local file instructions 2025 (QC 103617) and Local file/master file 2025 (QC 103618).

5. Accordingly, LCR 2015/3 is being withdrawn as it no longer reflects current law and has been superseded by ATO website guidance.

Commissioner of Taxation
18 December 2025

© AUSTRALIAN TAXATION OFFICE FOR THE COMMONWEALTH OF AUSTRALIA

You are free to copy, adapt, modify, transmit and distribute this material as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).

References

ATO references:
NO 1-19TCD526