Ultimate Beneficial Owner Filing Requirements in Italy

Ultimate beneficial ownership filing requirements in Italy mandates that all companies operating in Italy are required to report and maintain an ultimate beneficial owner.

The Legislative Decree 231/2007 has proposed a mandate that all business entities must file information pertaining to beneficial ownership (“UBO”) by March 15, 2021. The UBO shall be the person appointed by the company as official beneficiary for transactions held between the company and outside institutions. This information must be filed within 30 days of the incorporation date for new entities incorporated.

The filing must be done by managers or directors of the company, founder or administrators of trusts, etc. The information collected must be verified and must include the registered address of the organization, Italian tax code number, and place of business. Filing information must include:

• The nature of power and source to control the entity
• Ownership percentage of the company’s capital
• and source and nature of authority to legally represent the entity.

Employer Considerations:

All legal entities must identify their UBO’s properly by implementing a process for identification and reporting the UBO upon changes occurring in the shareholding pattern. Letters containing the beneficial ownership information must to be sent out to shareholders.