Tracing ownership across Hong Kong, the BVI and China
A worked ownership chain shows why local filings can name different people. Keep the calculation, evidence sources and applicable control test distinct.
By Matthew Lee
An ownership percentage can stay the same across a cross-border structure while the people identified under local filing rules differ. The practical task is to establish the chain, calculate the interests and apply the test relevant to the onboarding firm. A local beneficial ownership filing supports that work; it does not decide every institution's customer due diligence conclusion.
One worked chain
This fictional example isolates shareholding, without additional voting or control arrangements:
- Harbour Crest Trading Limited, a Hong Kong company, is wholly owned by Silvermine Bay Holdings Limited in the BVI.
- Silvermine Bay is wholly owned by Shenzhen Hongyuan Holdings Co., Ltd.
- The Mainland parent is owned by Zhou Jianguo (60%), Liu Min (25%) and Chen Hui (15%).
Because both intermediate links are 100%, Zhou's indirect interest in Harbour Crest is 100% × 100% × 60% = 60%. Liu and Chen likewise hold indirect interests of 25% and 15%. A different intermediate percentage would change the calculation, while multiple ownership paths would need to be considered together.
Evidence at each layer
| Layer | Evidence identifying the next holder | Further evidence commonly needed |
|---|---|---|
| Hong Kong customer | Latest annual return and current member records | Changes since the return, relevant control evidence and client-held records |
| BVI holding company | Current register of members through an appropriate authorised source | Corporate member details, share rights and relevant control arrangements |
| Mainland parent | Company record showing registered shareholders | Current changes, contribution details and supporting ownership declarations |
An incorporation or search certificate establishes the entity within its scope. It does not bridge a missing ownership link. The company number, source and date should connect each record to the ownership chart so the calculation can be reproduced.
Why the lists can differ
For this example, Hong Kong's AMLO shareholding test is more than 25%, the Mainland beneficial ownership filing test is 25% or more, and the BVI filing framework includes a 10% threshold. These are shareholding comparisons only; voting rights and other control tests also need assessment under the relevant rules.
| Person | Indirect interest | Hong Kong AMLO shareholding test | Mainland filing threshold | BVI filing threshold |
|---|---|---|---|---|
| Zhou Jianguo | 60% | Meets it | Meets it | Meets it |
| Liu Min | 25% | Does not meet it on shares alone | Meets it | Meets it |
| Chen Hui | 15% | Does not meet it on shares alone | Does not meet it on shares alone | Meets it |
Liu's 25% illustrates the boundary. Her absence from a Hong Kong shareholding-only result would not contradict her inclusion under another filing test. Additional control rights or the accepting firm's risk assessment may still require her identification and verification. The same principle applies to Chen: a percentage comparison does not settle whether other means of control exist.
Access is another question
Hong Kong's significant controllers register is company-held. BVI member evidence and beneficial ownership applications have their appropriate authority and access conditions. Mainland central beneficial ownership filings are distinct from publicly available shareholder records. A company declaration or administrator-issued record should remain labelled by its source, rather than being presented as an official restricted-register response.
How the Fill Easy email bot helps
An approved organisational sender can email agent@fill-easy.com with the entities, jurisdictions, identifiers and case reference, specifying the available registry records needed at each layer. Availability, access requirements, price and turnaround are confirmed at acceptance, and the agent asks for clarification where needed.
Retrieved PDFs arrive in the same thread with source, retrieval time and request ID. An optional summary references the underlying records. Client-held ownership evidence and individual verification follow their appropriate processes. The reviewer retains the chart, calculation and evidence supporting each link, then applies the accepting firm's ownership and control requirements.