Qatar (QA)

Jurisdiction Overview

IDQuestionAnswer
477 *BO Record: Does the registration of domestic limited partnerships comprise information on the beneficial ownership of all partners? No, for some partnerships no beneficial ownership information is recorded.
 Data Date: 2017

Notes

 
The practice of registering beneficial ownership includes only two layers: "When an entity first applies to be licensed and registered in the QFC [Qatar Financial Centre], the entity must provide ownership (including beneficial) information to the QFC CRO [Corporate Registry Law] and QFC Authority. In practice, the QFC CRO will look through two entity levels to determine this ownership information. It is noted that this practice is not consistent with the requirements under the standard or with the Qatar AML Law, however, this appears to be a small gap because [...] licensed firms and authorised firms in the QFC must comply with obligations set out QFCA Rules and QFCRA General Rules which includes disclosing changes in beneficial ownership and control to the QFC Authority and QFC Regulatory Authority." (GF 2017: 41 [TJN's-note]). In its 2017 report, the Global Forum didn't mention the limited partnerships that need to registered in the QFC. However, based on it 2013 report, there is evidence that such limited partnerships can be created. Given the two layers' practice and the weakest link principle, we conclude there is no sufficient beneficial ownership registration for these kind of limited partnerships.
 
Beneficial ownership registration seems to be required, however, with regard to partnerships that are not subject the QFC, "Pursuant to the CCL and CRL [Commercial Registry Law], entities are required to provide ownership information (including beneficial ownership information) to the Commercial Register when registering and must notify the Ministry of Economy of any changes" (Ibid: 40).

Sources

GF 2017: 26-38.