Dear all,

In corporation with our partner law firm Tasić & Partners, we inform you on obligation to establish the Central record of real owners and registration of an electronic address.

Article 17 of the Law on the Central Record of Real Owners (“Official Gazette of the Republic of Serbia”, No. 41/2018, hereinafter: “CRRO“) stipulates that the Business Register Agency (hereinafter: the ” BRA “) to establish the Central Record of the Real Owners of Legal Entities and Other Entities Registered in the Republic of Serbia (hereinafter: “Central Record“) no later than December 31, 2018.

Accordingly, the same article stipulates that the person authorized to represent in the registered entity (hereinafter: the “authorized person“) is obliged to register the necessary data for the registered entity by January 31st, 2019 at the latest established by December 31st, 2018.

The data to be provided are prescribed by Article 5, paragraph 2, of the CRRO, which are:

• for a domestic natural person – personal name, unique registration number of citizens and country of residence
• for a foreigner – personal name, passport number and country of issue and / or personal number for foreigners and / or identity card number of the foreigner and the country of issue in accordance with the regulations governing the conditions for entry, movement and stay of foreigners on the territory of the Republic of Serbia, day, month, year and place of birth, country of residence and citizenship
• for refugees or displaced persons – personal name, number of ID card, day, month, year and place of birth and country of residence
• the basis for acquiring the status of the real owner of the Registered Entity.

The actual owner of the registered entity can be:

• a natural person who is directly or indirectly the holder of 25% or more of the shares, shares, voting rights or other rights, on the basis of which he participates in the management of the Registered Entity, or participates in the capital of the Registered Entity with 25% or more of the shares
• a natural person who directly or indirectly has a predominant influence on the conduct of business and decision-making
• a natural person who indirectly provides or secures funds to the Registered Entity and, on that basis, significantly influences the decision-making of the Managing Authority of the Registered Entity when deciding on financing and operations
• a natural person who is a founder, a trustee, a protector, a beneficiary, if any, and a person holding a dominant position in the management of a trust, or in another person of foreign law
• a natural person registered for the representation of cooperatives, associations, foundations, foundations and institutions, if the authorized person for representation was not registered by another natural person as the actual owner.

Also, we remind you that since October 1, 2018 you are obliged to have a registered e-mail address in accordance with Article 21 of the Company Law (“Official Gazette of the Republic of Serbia” No. 36/2011 , 99/2011, 83/2014 – other Law, 5/2015, 44/2018 and 95/2018).

In line with all of these, please contact us directly in order to fulfill your legal obligations.

For any additional questions, you can contact our consulting team.