Under the BO Regime BVI companies and limited partnerships must collect, maintain and (subject to certain exemptions) file up-to-date beneficial ownership information with the BVI Registrar of Corporate Affairs. Companies whose shares are listed on a recognised exchange (which includes, among others, the London Stock Exchange, NYSE, NASDAQ and the Hong Kong Exchange) are exempt from the filing obligation, as well as a BVI company that is a subsidiary of a company that is listed on a recognised exchange. For these purposes, a legal entity is a subsidiary of another legal entity (the “parent”, ie the listed company) if the parent holds, directly or indirectly (i) a beneficial interest in 75% or more of the shares in the subsidiary; or (ii) 75% or more of the voting rights in the subsidiary.
