While the various emergency and interim measures enacted by the Polish government in the face of the Covid-19 epidemic under the Anti-Crisis Shield label afforded enterprises some breathing room as regards the deadline for Central Actual Owner Register filings, the deadline – which had been moved back to 13 July 2020 – is approaching again, and for those businesses that yet have to fulfil this statutory duty, the matter merits attention.

By 13 July, most Polish companies must file with this register the details of their beneficial / actual owners. The legislature has made sure to duly motivate those concerned – enterprises which fail to disclose beneficial owner information, or do so after elapse of the deadline, face penalties of up to PLN 1 mln. As they strive to fulfil this duty, the directors of some companies – especially those who have elaborate capital structures and/or foreign affiliates – may encounter significant difficulty in identifying their actual owners already as they try to deconstruct the definition [...]


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