Identification Of Beneficial Owner For A Single-Member Limited Liability Company

Answer

Pursuant to Clause 1, Article 17 of Decree No. 168/2025/ND-CP:

“1. Criteria for identifying the beneficial owner of an enterprise

The beneficial owner of an enterprise with legal person status (hereinafter referred to as the “beneficial owner of the enterprise”) is an individual who meets any of the following criteria:

(a) An individual who directly or indirectly owns at least 25% of the charter capital or at least 25% of the total voting shares of the enterprise;

(b) An individual who has the right to control the adoption of at least one of the following matters: Appointment, dismissal, or removal of the majority or all members of the Board of Directors, the Chairperson of the Board of Directors, the Chairperson of the Members’ Council; the legal representative, the Director or General Director of the enterprise; amendments or supplements to the enterprise’s charter; changes to the company’s organizational and management structure; reorganization or dissolution of the company.”

Pursuant to Point (c), Clause 1, Article 18 of Decree No. 168/2025/ND-CP:

“1. The enterprise founder and the enterprise shall declare and notify the provincial-level Business Registration Authority of the information on the beneficial owner(s) of the enterprise as follows:

…

(c) The individual who is the owner of a single-member limited liability company.”

In this case, you are the sole owner holding 100% of the charter capital of the Single-Member Limited Liability Company and fully satisfy the criteria for being identified as the beneficial owner. Accordingly, under the regulations, you are the sole beneficial owner of the company and must declare such information using Form No. 10 issued together with Circular No. 68/2025/TT-BTC.