Beneficial ownership filings: common mistakes we see in WFOE files

The rule in brief

Companies must identify individuals who hold 25% or more of equity, profits or voting rights, or who otherwise control the company, and file them with SAMR. Changes must be updated within 30 days.

Common mistakes

• Stopping at the parent company instead of looking through to the individuals
• Forgetting control by other means, such as board appointment rights
• Not updating the filing after a group restructuring