India (IN)

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: 2019

Notes

 
It appears that the 2019 amendments dropped the provisions allowing senior managers to be identified as beneficial owners. According to Mondaq: "Most of the major concerns which emanated from the Rules, as notified in June 2018, seem to have been addressed. For instance, the Rules initially provided that where the member is a company/ partnership firm having significant beneficial ownership, and no individual is identified as a significant beneficial owner, the senior managing official of such company/ partnership firm would be considered as the significant beneficial owner.[...] These provisions have been dropped in the amended Rules" (mondaq.com).

Sources

http://www.mondaq.com/india/x/804156/Corporate+Commercial+Law/MCA+Introduces+Amended+Rules+For+Significant+Beneficial+Ownership
 
http://www.mondaq.com/india/x/785144/Corporate+Commercial+Law/The+Law+Pertaining+To+Significant+Beneficial+Owner+In+Companies