Netherlands (NL)

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)? Yes, a senior manager may be registered as a beneficial owner, making it impossible to distinguish him/her from a real beneficial owner.
 Data Date: 2019

Notes

 
"If nobody qualifies as a UBO based on the ownership or control requirement, or if there's any doubt as to which individuals are UBOs, the individual(s) that hold the position of senior managing official(s) will be considered the UBO(s)" (mondaq.com).

Sources

https://www.rijksoverheid.nl/onderwerpen/financiele-sector/ubo-register
 
http://www.mondaq.com/x/826326/Corporate+Commercial+Law/Netherlands+UBO+register+is+expected+to+go+live+in+January+2020