More detailed information about the UBO to be provided by 31 August 2021

This extension of the information to provide was introduced by a Royal Decree which entered into force on 11 October 2020 but the Finance administration had granted a grace period until 30 April 2021.

However, the deadline for the uploading of supporting documents and the annual confirmation of the information in the UBO register has been extended to 31 August 2021.

What information is involved?

1. Supporting documents

From now on, "any document that supports and demonstrates the adequacy, accuracy and topicality of the registered data" must be included in the UBO register.

This includes a copy of the deed of incorporation and articles of association of the company, the shareholders' register, a shareholders' agreement, the share transfer agreements, etc.

This also means that these documents must also be added each time changes are made to the register, in order to confirm these changes.

However, these documents are only accessible to the competent authorities.

These documents have to be uploaded at the time of the initial registration or at the time of the annual confirmation of the UBO register which has to take place at the latest on 31 August 2021.

2. Participation percentages of indirect UBO's

From now on, all shareholding percentages or voting rights that the indirect UBO holds or controls in the obliged entity and in each intermediary entity must be recorded in the UBO register.

An indirect UBO means, any individual who owns or controls the obliged entity through one or more intermediary legal entities.

Should you wish to receive more information on this topic or be assisted with the registration or the confirmation of the UBO register, please do not hesitate to contact our specialists via info@seeds.law.