GmbH – limited liability company
Both initial registration, as well as annual filings can be necessary. Germany recently implemented the transparency register by an amendment of its Money Laundering Act with effect as of June 27, 2017. Companies such as GmbH, AG, KG and KGaA have to submit to the transparency register specific information about their beneficial owner if a natural person directly or indirectly (with a multi-level participation structure) holds more than 25 percent of the capital or voting shares or exercises control in a comparable manner.
With another amendment of the Money Laundering Act with effect as of August 1, 2021, such a filing with the transparency register is required in any case where the 25 percent threshold is triggered, regardless of whether or not the same information can already be retrieved from the German commercial register or any other public register.
If no shareholder holds more than 25 percent of the capital or voting shares or exercises control in a comparable manner, the managing directors of the company need to be registered with the transparency register instead.
