All relevant Dutch entities have to register their UBOs with the Dutch UBO register prior to March 27, 2022. This requirement also applies to all Dutch limited partnerships (‘commanditaire vennootschappen’ or ‘CVs’).
In the past, there was no requirement to register a CV with the Dutch trade registry if did not perform any business activities in The Netherlands. A lot of CVs with no real nexus to The Netherlands have therefore not been registered with the Dutch trade registry at their formation. However, since the implementation of the Dutch UBO register, it is mandatory (i) to register all CVs – with or without any business activities in The Netherlands – with the Dutch trade registry and (ii) to register their UBOs with the Dutch UBO register. It is expected that there are quite some CVs in existence which have not be registered yet. In order to avoid/mitigate any penalties and other sanctions, it is time to act now and have these CVs and their UBOs registered asap.
For CVs which were already registered with the Dutch trade register prior to the implementation of the UBO register, the deadline of March 27, 2022 applies; i.e. they must register their UBOs with the Dutch UBO register prior to that date.