In accordance with the Beneficial Owner Central Registry legal regime (BOCR), laid down in Law no. 89/2017 of August 21 and Ordinance no. 233/2018 of October 1, the so-called “Relevant Entities”, which include associations, cooperatives, foundations, civil and commercial companies, as well as any other collective entities that carry on an activity or legal transaction for which a tax identification number (NIF) is required, branches of multinational corporations or foreign law bodies that are active in Portugal, trusts and branches of financial companies registered in Madeira’s free trade zone, are legally required to register in the BOCR up to April 30 2019.

In the event of failure to comply with this obligation within the above deadline, the relevant entities shall be prevented from:

i) Distributing profits for the financial year, or making advanced payments on account for profits in the course of the financial year;

ii) Concluding contracts, public work contracts, or acquisition of services and goods with the Portuguese government, municipalities and other public entities, including its renewal (if a contract is in force);

iii) Biding for the concession of public services;

iv) Receiving support from the European Structural Funds and public investment;

v) Being part of any business (whether for consideration or free of charge) relating to the transfer of ownership, or the constitution, acquisition or disposal of any other rights in rem to use or guarantee any property;

In addition, failure to comply with the registration shall also trigger the application of fines between € 1.000,00 and € 50.000,00.

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[Photo: Luca Dugaro, available at:]