Step 1 · Assess
A business we would hold ourselves.
Four functions, all carried out for companies we hold an interest in.
We hold what we hold with our own money, which is the whole distinction from an investment firm. There is no fund, no mandate from outside investors and no pooling of anybody else's capital, and consequently no FSMA authorisation, because none of what we do requires one. Approaches asking us to manage or place money are declined.
A business we would hold ourselves.
With our own capital.
With a long horizon.
Through the management function.
What the service actually is.
By identified people.
What was done, and when.
On a defensible basis.
A management fee has to correspond to services actually rendered, by identifiable people, at a price that can be justified. Fees without substance get disallowed, and the adjustment hits the paying company as well as the one invoicing. So we record what was done, who did it and how the fee was arrived at, rather than issuing a round number each quarter.
Where a company holds a directorship in Belgium it must designate a permanent representative, a natural person who carries the same liability as if they held the mandate personally. That is not a formality: it puts an individual's name and exposure behind the seat. We designate one and we declare conflicts of interest as the Code requires.
Whether to accept it at all.
A named individual designated.
With the duties that attach.
Conflicts, as the Code requires.
Prepared and filed in format.
Confirmed every year.
Consolidation checked.
Tax and audit to the professions.
The UBO register requires an annual confirmation and is the obligation most often missed, because nothing visible reminds anyone. Consolidated accounts become necessary once statutory thresholds are crossed, which a group can do without noticing. Both are handled rather than discovered. Accountancy and tax themselves go to an ITAA-registered professional.
An enquiry costs nothing, and we will say quickly if it is outside what we do.