On the basis of the 4th Anti Money Laundering Directive (“AMLD”) all EU member states have to introduce a publicly accessible register in which information of (in)direct individual owners of more than 25% beneficial ownership (“UBO’s”) will be recorded. Other indicators for qualification as a beneficial owner are the right to exercise more than 25% of the voting rights or the right to remove the managing directors. If no UBO can be qualified, it is also possible that managers of a top entity are considered to be a UBO.

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The Dutch Civil Code (“DCC”) has been amended in respect of the size criteria of companies. An additional qualification was added by means of article 2: 395a DCC : the micro-sized company. The criteria for such company are as follows:

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