Austria EUR 35,000.00 (at least half of the amount must be paid in on incorporation of the company when a new GmbH is being formed rather than acquiring a shelf company).

Another type of GmbH ('privileged GmbH') with a lower initial share capital requirement (which increases at a later stage) is available but is not commonly used by inward investors.

China Generally none.

Special requirements may apply in specific sectors (e.g. for financial institutions).

Czech Republic The minimum share capital for a limited liability company is CZK 1, for a joint stock company it is EUR 80,000 or CZK 2,000,000.

At least 30 % of the share capital must be paid up before registration of the company with the Commercial Register.

England & Wales Can be less than £1.

France Cannot be less than EUR1.

Germany EUR25,000.00, at least half of this must be paid on incorporation when a new company is being formed (rather than adopting a shelf company).

There is another type of company with a lower share capital requirement is available but is not commonly used by inward investors.

Hong Kong No.

Hungary 3,000,000 HUF (approximately EUR 9,090.00).

Ireland Can be less than €1.

Netherlands There is no minimum of share capital to be paid up at or prior to incorporation. It is common practice to have an issued share capital of EUR 1, to be paid up after a bank account in name of the B.V. has been opened.

A minimum share capital of EUR 0,01 (one cent) is possible.

Poland Limited liability company – at least 5,000 zlotys

Joint stock company – at least 100,000 zlotys

Singapore At least one share of a company must be issued, hence the minimum share capital is typically one dollar in the currency of shareholder’s choice (unless a higher capital requirement is prescribed is a required license for a specific industry).

Slovakia An LLC has to have the minimum share capital of EUR 5,000.

The minimum share capital required for a JSC is EUR 25,000.

The minimum share capital required for a JSA is EUR 1.

United Arab Emirates There is currently no minimum share capital requirement for an LLC onshore. The capital should, however, be appropriate for the proposed business model and the DED has the right to impose a minimum share capital in its sole discretion. It is common for an LLC to have a share capital of minimum AED 100,000.

- There are variations between free zones depending on the nature of activities conducted.

Austria No.

China No.

Czech Republic No.

England & Wales No.

France No.

Germany No.

Hong Kong No.

Hungary No.

Ireland Subject to certain exceptions, companies must have at least one director who is resident in an EEA member state.

Netherlands No.

Poland No.

According to the new provisions which came into force in March 2018, the financial statements of a company can be submitted to the registry court only via a special platform which requires that at least one member of the Management Board has a PESEL number (national identification number used in Poland). However, it is possible to obtain a PESEL number for non-domestic directors.

Singapore Yes. At least one director that is ordinarily resident in Singapore is required.

Slovakia No, in case of EU or OECD citizens. Non-EU or non-OECD citizens requires residence permit.

United Arab Emirates In accordance with the UAE Companies Law of 2015 (as amended), an LLC is managed by 'Manager(s)'.

The DED does not currently require that a Manager be a UAE resident. However, for companies incorporated in some of the free zones, the applicable Registrar requires the Manager to be a UAE resident. In addition, UAE banks will not open a current account and issue a cheque book for a legal entity unless the Manager has obtained a UAE residency visa.

Austria No.

China Generally not.

Only for sectors subject to respective investment access control. A minimum Chinese participation may be needed.

Czech Republic No.

England & Wales No.

France No.

Germany No.

Hong Kong No.

Hungary No.

Ireland No.

Netherlands No.

Poland No.

Singapore No.

Slovakia No.

United Arab Emirates In accordance with the UAE Companies Law, 51% of a LLC’s total share capital needs to be held by a UAE national. Free zones allow 100% foreign ownership. However, the Federal Decree No. (19) of 2018 on Foreign Direct Investment (the “FDI Law”) came into force in November 2018. The FDI Law provides a framework for the UAE Cabinet to permit foreign shareholders to own up to 100 of companies in certain designated sectors. The "positive list" of industries where such a higher level of foreign ownership will be permitted was published in July 2019 and covers a range of commercial activities in the agricultural, manufacturing and service sectors. Free zones allow 100% foreign ownership..

Austria Not for small companies, but for medium and large companies.

Financial statements need to be audited if two of the following criteria apply: the balance sheet total exceeds EUR 5 million or the revenues exceed EUR 10 million or the average number of employees exceeds 50.

China Yes, annually.

Czech Republic For medium-sized and large companies - yes. For small companies – yes, if one (in case of a joint stock company) or two (in case of any other type of company) of the following three thresholds are exceeded:

- annual total balance sheet amount of CZK 40,000,000;
- annual net turnover of CZK 80,000,000;
- an average number of 50 employees.

England & Wales No for small companies, yes for medium and large companies. Financial statements exempt from the audit requirement if two of the following criteria are met:
- annual global turnover of no more than £10.2 million
- assets worth no more than £5.1 million
- 50 or fewer employees on average

France Yes, the appointment of statutory auditor is mandatory if at least two of the three following thresholds are exceeded:

- annual balance sheet total > EUR4,000,000;
- revenues excluding tax > EUR8,000,000; and
- average number of employees > 50.

In a group, the controlling company must designate a statutory auditor if the thresholds are exceeded by the group as a whole (including controlled companies), except in the case where the group head company is itself controlled by a company that has appointed a statutory auditor. Controlled companies are also required to appoint a statutory auditor if two of the following thresholds are exceeded (annual balance sheet total > EUR2,000,000; revenues excluding tax > EUR4,000,000; and average number of employees > 25).

The statutory auditor is appointed for a fixed term of six years (which can be reduced to three years in case of voluntary appointment or in case of appointment of statutory auditor(s) in a group).

Germany Not for small companies, yes for medium and large companies. Financial statements need to be audited if two out of the following three criteria are met:
- annual total balance sheet amount of at least EUR 6,000,000
- annual turnover of at least EUR 12,000,000
- at least 50 employees.

Hong Kong Audited financial statements are required for all companies incorporated in Hong Kong, including companies falling within the reporting exemption, unless the company is dormant.

Hungary As a basic rule, the auditing of accounting documents shall be statutory for all companies keeping double-entry books.

However, the auditing of accounting documents shall not be statutory if both of the conditions below are satisfied:
- the company’s annual net sales did not exceed 300 million HUF (approximately 909.090,- EUR) on the average of the two financial years preceding the financial year under review, and
- the average number of employees of the company of the two financial years preceding the financial year under review did not exceed 50 persons.
When establishing a new entity, a prognosis shall be made whether these thresholds will be reached.

Ireland

Netherlands Not for small companies, yes for medium and large companies.

Financial statements need to be audited if two of the following three requirements are met:
- annual global turnover of more than EUR 12 million
- assets worth of more than EUR six million
- 50 or more employees on average.

Poland Limited liability company: audit of financial statements is required in the case of those limited liability companies, who in the previous financial year for which financial statements were prepared, met at least two of the following conditions:
- average annual employment in full-time equivalents amounted to at least 50 people,
- the total balance of assets at the end of the financial year was the equivalent in Polish currency of at least EUR 2,500,000,
- net revenues from sales of goods and products and financial operations for the financial year were the equivalent in the Polish currency of at least EUR 5,000,000.
Joint stock company: audit of financial statements is required in all joint-stock companies with the exception of joint stock companies in organization (prior to registration).

Singapore The revenue of the company for each financial year does not exceed S$10 million;
The value of the company’s total assets at the end of each financial year does not exceed S$10 million; and/ or
it has at the end of each financial year not more than 50 employees.
/it has at the end of each financial year not more than 50 employees.

Slovakia No for small companies, yes for medium and large companies.
In general, financial statements of the company need to be audited if two of the following criteria apply (as of the respective date of the financial statements and for the immediately preceding accounting period):

i. assets reported in the balance sheet exceeds EUR 2 million;
ii. net turnover exceeds EUR 4 million;
iii. the average number of employees exceeds 30.

United Arab Emirates Yes, in most UAE jurisdictions.

Austria The shareholders of a GmbH must be disclosed in a shareholders’ list with the commercial register. The shareholders have to be updated upon each change of shareholdings.

Ultimate beneficial owners have to be disclosed with the Austrian Beneficial Owner Register; other than that the disclosure of the ultimate beneficial owner will be required for 'know your client' checks by banks and other organisations and in some limited sectors for regulatory purposes.

China Yes, during incorporation procedures (ie ultimate controlling shareholder(s)).

Czech Republic Limited liability company: The shareholders have to be disclosed in the publicly available Commercial Register and, concurrently, in the Articles of Association the up-to-date wording of which needs to be published in the Collection of Deeds kept by the Commercial Register.

Joint stock company: Only 100% shareholders must be disclosed in the Commercial Register. However, the company is obliged to keep a shareholder´s list.

The disclosure of ultimate beneficial owners is obligatory, although the special register of beneficial owners is not public. The regulation is based on EU law (the Fourth Money Laundering Directive).

England & Wales Shareholders of a Limited company must be disclosed at Companies House. Ultimate beneficial owners may need to be disclosed, typically this will apply in respect of a UK subsidiary company if there is an individual with a majority of the ownership or voting rights of the overseas parent company.

France Yes, for the French limited liability company (SARL), the identity of the direct shareholders and their shareholdings into the company’s capital are disclosed in the bylaws. For the French (simplified) joint stock company (SA/ SAS) only upon registration as a list of subscribers must be filed with the Commercial Court. After registration, the list of the shareholders is disclosed in the share ledger which is not publicly available.

UBO declaration: relatively newly French regulation provides also for the obligation to disclose the identity of the “ultimate beneficial owner(s)” of the company. In this respect, all French unlisted companies shall disclose and file with the commercial court accurate and up-to-date information as regards to the list of their beneficial owners. From a French legal perspective, the company’s ultimate beneficial owners are defined as the natural person(s) who ultimately holds (either directly or indirectly) more than 25% of the share capital or of the voting rights of the Company.

Persons who can access to ultimate beneficial ownership information: the categories of persons who are authorized to access to the ultimate beneficial ownership document are the judges, customs officials, the investigators and inspectors of the French financial market authority, the operatives of French Treasury, or, under certain conditions, persons subject to measures designed to combat money-laundering and financing of terrorism. Moreover, French law lays down the terms under which any person who can evidence a legitimate interest may request disclosure of a company’s register of beneficial owners, if need be by filing a petition before the commercial court.

Germany Shareholder/s of a GmbH must be disclosed in a shareholders’ list in the commercial register, which is to be updated upon each change of shareholdings. Ultimate beneficial owners having a stake of at least 25% have to be disclosed in the transparency register due to Money Laundering Law.

Hong Kong Shareholders of a limited company must be disclosed to the Companies Registry. Every private company is required to keep and maintain a register of details of its shareholders.

Hungary Directive 2015/849/EU, the Fourth Anti-Money Laundering Directive, has been implemented in Hungary by the new anti-money laundering act (Act LIII of 2017). According to the directive, when engaging in a new business relationship, customers (legal persons, unincorporated organisations and fiduciary managers) have to provide information to service providers (e.g. credit institutions, lawyers) on their Hungarian and non-Hungarian beneficial owners as well. The hereby collected data on the beneficial owners will then be forwarded to the Transparency Register – which according to the resolution of the Hungarian Government, should have been set up by the 1st of January 2019, which however has not happened yet - by the given service provider. The Transparency Register will contain the beneficial owner’s name, date and place of birth, nationality, address or residence and the nature and extent of the economic interest. If the data of the beneficial owner is not provided, the service provider shall refuse to establish a business relationship. The competent authorities and financial intelligence units will have direct and unrestricted access to the data recorded in the Transparency Register.

Ireland Shareholders of a limited company must be disclosed at the Companies Registration Office. Ultimate beneficial owners may need to be disclosed, typically this will apply in respect of an Irish subsidiary company if there is an individual with a majority of the ownership or voting rights of the overseas parent company.

Netherlands Only 100% of shareholders of a BV must be disclosed.

The 100% shareholder will be registered as such at the Dutch Chamber of Commerce.

All shareholders will be registered in the shareholders’ register of the BV The information in the shareholders’ register is not publicly available.

Historically, ultimate beneficial owners have not generally needed to be disclosed other than for “know your client” checks by banks and other organisations and in some limited sectors for regulatory purposes. The implementation of a UBO register will follow as a consequence of the Fourth Money Laundering Directive.
The UBO register will become operational in the Netherlands in the beginning of 2020. The bill on the implementation of the UBO register was submitted to and approved by the House of Representatives and is currently before the Senate. Under this bill, natural persons who directly or indirectly hold more than 25% of the shares or bearer shares, voting rights or ownership interest or someone who has the direct or indirect ultimate control over the legal entity is considered an ultimate beneficial owner (“UBO”) and has to be registered at the Dutch Chamber of Commerce. Certain information in this register will be publicly available.

Poland Limited liability company: It is mandatory to disclose in the National Court Register those shareholders who own more than 10% of shares in the limited liability company. The shareholders have to be updated upon each change of shareholdings.
Ultimate beneficial owners do not need to be disclosed in the National Court Register.
However, disclosure of beneficial ownership might be required for tax purposes.

Joint stock company: It is mandatory to disclose a sole stockholder.

Singapore Every private company is required to keep and maintain a register of controllers which is private and will not be made available to the public.

Slovakia Shareholders of an LLC and founders of a Branch are disclosed in the commercial register. Shareholders of an LLC/founders of a Branch have to be updated upon each change of shareholdings.

A sole shareholder of a JSC/JSA is disclosed in the commercial register and has to be updated upon each change of shareholdings. List of shareholders of the JSA is publicly (online) available via central depositary.

Ultimate beneficial owners of most of the legal entities need to register its UBO with the Commercial Registry; this information is available only for selected authorities and is not publicly accessible. Furthermore, UBO does not generally need to be disclosed other than for “know your client” checks by banks and other organisations and in some limited sectors for regulatory purposes. However, companies wishing to carry on business with state entities (agencies) are required to be registered with the special publicly accessible register established for that purposes (UBO needs to be disclosed, too).

United Arab Emirates At present, the DED does not require details of all beneficial owners, but certain free zones do.

Austria Application for a tax identification number for the company within one month following the commencement of business activities at the latest.

China Yes.

Czech Republic Registration with the tax authorities is required within 15 days from the incorporation of the company (i.e. from the registration with the Commercial Register).

England & Wales HM Revenue & Customs will allocate a tax reference number following the registration
of the entity.

France VAT number will be allocated directly by the local Tax authorities to the Company further to the registration of the entity with the Trade and Companies Register.

Germany Registration at the local trade office (Gewerbeamt).
Registration at the local tax office (Finanzamt).

Hong Kong All companies and local branches must apply for business registration with the Inland Revenue Department.
Approximately 30 minutes over the counter or 2 working days by post upon submission of application.
Application must be made within 1 month of commencement of business.

Hungary The company will automatically receive an EU VAT number as well as a local tax number upon registration.

Ireland The Revenue Commissioners will allocate a tax reference number following the
registration of the entity.
No for small companies (including micro companies) and small groups, yes for medium and large companies.
Financial statements exempt from the audit requirement if two of the following criteria are met:

- annual global turnover of no more than €12 million
- balance sheet total of no more than €6 million
- 50 or fewer employees on average.

Netherlands Upon registration with the Dutch Chamber of Commerce it will provide the relevant information of registration to the Dutch Tax Authorities directly.

Poland No. After entering the entity (here: the company) into the National Court Register, the data covered by the entry is transferred via the ICT system to the Central Register of Entities - the National Register of Taxpayers.

Singapore From 1 January 2009, every entity that is established in Singapore (including companies and limited liability partnerships) has a unique identification number known as its Unique Entity Number (UEN). The UEN is used in all interactions with Singapore government agencies, and serves as the entity’s Tax Reference Number when interacting with the Singapore tax authorities (namely, the Inland Revenue Authority of Singapore, or "IRAS" in short).
- Limited liability companies will have to submit corporate income tax forms to IRAS every year

Slovakia Application for a tax identification number by the end of the next month following the registration of the LLC/Branch with the commercial register at the latest.

United Arab Emirates At present most onshore businesses are not subject to corporate taxes.

Nevertheless, VAT was implemented in the UAE on 1 January 2018, which resulted in certain mandatory and voluntary registration requirements with the Federal Tax Authority (FTA).

Any corporation conducting an economic activity for the purpose of generating income and whose value of the annual supplies in the UAE exceeds AED 375,000 over the previous 12-month period or is expected to exceed such amount in the next 30 days is required to register with the FTA.

A business may still apply to register for VAT if they do not meet the mandatory registration threshold, provided that the value of annual supplies in the UAE exceeds AED 187,500 over the previous 12-month period or is expected to exceed the voluntary registration threshold in the next 30 days.