Criteria for Identifying Beneficial Owner of Income

The Directorate General of Taxes (DGT) released an official guideline on 4 November 2025 outlining the criteria for an income recipient to be classified as a beneficial owner. The guideline applies to all taxpayers receiving income from corporations or other entities.

A beneficial owner is defined as the natural person who ultimately owns or controls the income. The criteria include: (1) holding at least 25 % of shares or voting rights, (2) entitlement to receive more than 50 % of net profit, (3) ability to direct decisions through agreements, and (4) being the ultimate beneficiary.

Establishing these criteria assists taxpayers and businesses in identifying reportable parties, improves tax compliance, and reduces the risk of tax avoidance.