A chart helps read the structure but does not prove it is true. For each level, establish ownership, decision-making and supporting sources.
Trace every relevant branch
Start with the client, identify direct shareholders and continue through legal entities to natural persons. Record votes and other means of control alongside shares. Do not stop at a holding company or foreign entity merely because Czech registers contain no further information.
Include countries, identifiers, percentages and sources at each level. Different rights may have different values. At an opaque level, “unknown” does not mean a zero holding.
Calculate indirect holdings
Under section 4(6) of the Beneficial Ownership Register Act, holdings along a chain are multiplied and branch results added. Someone holding 60% of a company that owns 50% of the client holds an indirect 30% through that branch.
If that person also directly holds 10%, the total for this shareholding assessment is 40%. Do not double-count a branch. Distinguish capital, votes and economic rights; automated calculations need the correct data type.
Control is more than multiplication
Separately, the law covers decisive influence over corporations that individually or jointly hold a relevant stake, and influence by other means. Someone controlling the parent may qualify as the client’s beneficial owner even where the calculated economic stake does not exceed 25%.
For example, a 51% holding in a parent that owns 30% of the client produces 15.3% mathematically. If the person actually exercises decisive influence over that parent, assess the separate control criterion too. Do not automatically exclude them because of multiplication.
Evidence, discrepancies and proportionality
Use relevant Czech registers and documents, suitable foreign equivalents and further trustworthy information. Client confirmation should be dated and specific. Check that evidence for important levels concerns a common effective period.
Complexity alone does not prove suspicion. Lack of an economic explanation, unclear control or repeated changes may increase risk and verification scope. A beneficial ownership extract is required where registration duties apply, but does not resolve missing links. Address gaps through cooperation, further verification and, where applicable, section 15 rather than inventing an owner.
Practical steps
- Chart all relevant ownership and control branches.
- Substantiate persons, rights and values at each level.
- Calculate indirect holdings and assess control separately.
- Compare the result with the register and resolve gaps.
Illustrative scenario
An office finds a 30% indirect holding and another person controlling a company with a relevant stake. It assesses and explains both legal routes separately.
When the situation differs
The calculation produces 15.3%, so software excludes the individual without examining decisive influence over the parent.
What to document
- A dated chart with identifiers and sources.
- Branch calculations and the rights being calculated.
- A separate control conclusion and register comparison.
Common pitfalls
- Stopping at a foreign parent.
- Using multiplication as the sole legal analysis.
- Mixing historical and current holdings.
Frequently asked questions
Is a holding below 25% always irrelevant?
No. Other statutory criteria, particularly decisive influence, must be assessed.
Does an ownership chart prove the structure?
It is a useful summary. Material information must be supported and verified according to risk.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
- Legal entity and beneficial owner information · PDF / Word
- Registered offices, formation and company services including shelf companies →
Complete client information online
Where to go next
- Beneficial owners: establish first, then verify — Distinguish identifying a beneficial owner, verifying identity and substantiating why the person owns or controls the company.
- Beneficial owners of a simple Czech s.r.o. — Verify direct shareholders, the greater-than-25% threshold and other forms of decisive influence.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 9 odst. 2 písm. b), c), odst. 3; § 9a · accessed 2026-10-04 - Zákon č. 37/2021 Sb. — aktuální znění e-Sbírky ↗
§ 4 odst. 1–6; § 5 · accessed 2026-10-04 - FAÚ: Metodický pokyn č. 3 — zjišťování skutečného majitele ↗
Zjištění a ověření skutečného majitele, 25. 4. 2025 · accessed 2026-10-04
Editorial work and source checks are not independent legal approval of your particular process. Compare the conditions and exceptions with your own circumstances.