Brazil (BR)

Jurisdiction Overview

IDQuestionAnswer
388 *Can a senior manager ever be registered as a beneficial owner (because no individual passed the threshold to be considered a beneficial owner)? No, even if the senior manager is registered (because no individual passed the threshold to be considered a beneficial owner), he/she is registered as such, but not as an ordinary 'beneficial owner'.
 Data Date: 2018

Notes

 
The law does not specify what happens if no one passes the threshold to be considered a beneficial owner (GF 2019: 47).

Sources

http://normas.receita.fazenda.gov.br/sijut2consulta/link.action?visao=anotado&idAto=97729#1954228
 
Normative Instruction 1863/2018, Art. 3 and 8