Hold on our own account
Our capital, our purposes, nobody else's money.
East Flanders · Holding company since 2018
Built to sit
Built to sit
between.Not to hide.
A holding company stands between people and assets by design. The beneficial ownership register exists to see straight through it, and both of those things are legitimate. Interposition is lawful. Opacity is not. So our entry stays adequate, accurate and current.
- 2018formed in
- 25%the threshold
- 1 monthto update
- Yearlyconfirmed
What we do
Four things, stated plainly
A holding company does less than people imagine, so here is exactly what this one does and does not do.
Holding participations
Holding participations in companies on our own account, and nobody else's.
See the programBeneficial ownership
Keeping the beneficial ownership entry declared, evidenced, updated and confirmed.
See the programWhat we are not
Not an investment firm, not a nominee, not a company services provider.
See the programRecords and filings
Annual accounts and statutory filings, done when they are due.
See the program
How it works
How we work
Hold on our own account and say so plainly, declare who ultimately owns and controls the company with documents to evidence it, register any change within a month, and confirm the entry every year whether or not anything has moved.
Declare and evidence
Beneficial owners, with supporting documents.
Update within the month
Any change registered, not noted for later.
Confirm annually
Even in a year when nothing changed.
Working together
How we are organised
A holding company has no price list. Prices quoted anywhere on this site would be in euro. What follows is what the company does, and does not, do.
Participations
Interests held with our own capital.
- Held on our own account
- No third-party money
- No pooled investment
- Long-term rather than traded
- Records kept properly
The register
Beneficial ownership declared, evidenced and confirmed.
- Ultimate owners identified
- Supporting documents filed
- Changes within one month
- Confirmed at least annually
- Directors personally accountable
What we will not do
The requests a holding company attracts.
- No nominee shareholdings
- No nominee directorships
- No company formation for others
- No investment services
- No structure built to obscure
Every engagement is quoted after a free consultation. No subscription.
How we work
Interposition is lawful. Opacity is not.
SILYMASEMA SRL was created on 8 June 2018 and is registered with the Crossroads Bank for Enterprises under number 0697.754.850, with its registered office at 8A Holstraat in Buggenhout, East Flanders. Its sole registered activity is that of a holding company, holding participations on its own account.
A holding company exists to sit between people and the things they own, and the beneficial ownership register exists to look straight through that structure. Those two facts are often presented as being in tension and they are not. Holding assets through a company is an ordinary and lawful way to organise them. Concealing who ultimately stands behind the company is a different thing entirely, and the register is how the law tells the two apart. So the obligations get treated here as substantive rather than administrative: declare the natural persons who ultimately own or control the company, in principle anyone above a quarter of the shares or voting rights along with anyone controlling by other means, file documents evidencing that the information is adequate, accurate and current, register changes within a month, and confirm the entry at least annually even in a year when nothing has moved. Fines fall on directors personally. One widespread belief worth correcting: the register is not browsable by the general public, because a European court ruling in 2022 struck that access down. It is open to authorities, to firms doing customer due diligence, and to those showing a legitimate interest.
Frequently asked
The questions we get most
What exactly is a holding company?
A company whose business is holding participations in other companies rather than trading itself. That is this company's sole registered activity. It holds interests on its own account, with its own capital, for its own purposes. It does not pool other people's money, hold assets for third parties or take positions on anyone else's behalf, and the narrowness of that description is deliberate rather than coy.
Who has to be declared as a beneficial owner?
The natural persons who ultimately own or control the company. In principle that means anyone holding, directly or indirectly, more than twenty-five per cent of the shares or the voting rights, together with anyone who exercises control by other means. Where no such person can be identified, the senior managing officials are declared instead. The test is about ultimate control, so ownership through intermediate companies is traced through rather than stopping at the first layer.
Is the Belgian beneficial ownership register public?
No, and a great many people believe it is. The provision of the European framework giving the general public access was declared invalid by the Court of Justice of the European Union in November 2022. Access now runs to competent authorities, to obliged entities carrying out customer due diligence, and to persons who can demonstrate a legitimate interest. So the information is reachable by those who need it and not simply browsable by anyone.
How often does the entry have to be touched?
More often than most people expect. Any change has to be registered within one month of happening, and the entry has to be confirmed at least once a year even if nothing at all has changed. Supporting documents evidencing that the information is adequate, accurate and current have to be filed as well, so it is not enough to type a name into a form. Administrative fines for failing can be imposed on directors personally.
Will you act as a nominee shareholder or director for us?
No. We do not act as nominee shareholder or nominee director for anyone, we do not form companies for third parties, and we do not provide arrangements whose purpose or effect is to obscure who ultimately owns or controls something. That is not a service this company offers and the register is precisely the mechanism designed to make such arrangements visible.
Are you an investment firm?
No. We do not manage money for anyone else, do not provide investment services or advice, do not solicit funds from the public, and hold no authorisation from the Financial Services and Markets Authority. Nothing on this site is an offer, invitation or inducement to invest, and we forecast no financial return of any kind. The word holding attracts approaches that assume otherwise, which is why it is written down here.