Beneficial ownership disclosure workbook
Example use of scenario
A regulator outside the UK wants to explain their understanding of the UK's beneficial ownership declaration requirements to a colleague.
The UK has a Persons of Significant Control (PSC) register where significant control or ownership of domestic companies is recorded. Ownership or control (direct or indirect) of over 25% of a UK company is always considered significant.
The regulator and their colleague examine the scenario and establish that both companies are registered in the UK (the fictional flag acts as a placeholder). They work from the declaring company at the bottom of the diagram, upwards through the ownership chain, deciding which individuals and companies would need to be included in its UK PSC declaration.
Scribbling over their copy of the diagram, the regulator explains that, according to the UK’s legal framework, the declaring company would only need to disclose Company A in its declaration: as Company A is a ‘registrable relevant legal entity’ holding ‘75% or more’ of shares and 2 voting rights. Person 1 would not be disclosed as a PSC by the declaring company. Person 1 would be declared as a PSC of Company A in its declaration.