On the 12th of April 2022 the Registrar of Companies published the following clarifications regarding the register of Real Beneficiaries:
1. Cases of companies that have submitted an application for strike-off or liquidation after 12/03/2021 in accordance with the Directive 112/2021.
Companies that have applied for their strike-off in accordance with section 327 (2A) (a) of the Companies Law or that the liquidation process started after 12/03/2021, are not excluded from obligation to submit information of their real beneficiaries.
2. Cases of companies where an objection has been filed by a competent authority and the company continues to be registered.
Companies that applied their strike-off before 12/03/2021, are excluded from the obligation to submit information of their real beneficiaries in accordance with the provisions of the Directive. The exception applies even in the event that an objection is lodged by a competent authority and the company continues to be registered. Such company will still be excluded from the obligation to submit information of their real beneficiaries.
3. Cases of companies that did not apply for strike-off but received a letter from the Registrar of Companies before 12/03/2021 that the company will be struck-off due to non-compliance and such company is not yet struck-off (considered as inactive).
Companies that did not apply for strike-off but received a letter from the Registrar of Companies before 12/03/2201 that the company will be struck-off due to non-compliance, but is not yet struck-off, are not exempted from the obligation to submit information of their real beneficiaries.
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Corporate Department