25 percent ownership and control by other means
Beneficial ownership has two limbs. One is ownership of 25 percent or more, and the other is control by other means, including where the percentage is lower.
Quick answer
A tax practice that stops at 25 percent will miss the person who controls the company with a smaller holding. A practice that only looks for controllers will miss a silent 40 percent holder. Write both limbs on the file. More than one person can qualify, and each individual the program requires is a separate client-pays check.
People search “beneficial ownership 25 percent control” when a tax practice finds one shareholder at 25 percent and closes the file without asking who controls the company. Checked against AUSTRAC's page on ownership and control on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. The definition, including both limbs, is what is a beneficial owner?. Why the list is often plural is can there be more than one beneficial owner?. The sector map is /tranche-2.
Two doors onto the list
Beneficial ownership 25 percent control is one test with two doors, and firms keep using only the first. Ownership of 25 percent or more puts a person on the list. Control by other means can put a person on the list even when they own less, or when their holding is indirect. Closing the file at the first percentage that prints is half the job.
Indirect holdings still count toward the percentage. A person who owns through a holding company is not excused because their name is absent from the trading company's first page. Shares through a chain are covered on the shares page. This page is the pair of limbs.
- Count 25 percent as ownership. Anyone who ultimately owns that much is in on the ownership limb.
- Then ask control. Who appoints the board, who directs the decisions, who the others actually follow.
- Under 25 percent is not automatically out. Control can add them. Lack of control can leave a small holder out.
- Record the limb. Write ownership or control next to the name so the file shows why they are there.
A company a tax practice will recognise
Picture a proprietary company with three names. The percentages and the control story do not point at the same person. The file should be able to hold both answers without forcing a single winner.
Ownership and control on one company. This table does not reproduce AUSTRAC's ownership and control guidance.
| Person | Limb | If you only did the percentage |
|---|---|---|
| Owns 40 percent, no special rights | Ownership | You would include them, correctly |
| Owns 25 percent through a holding company | Ownership, indirect | You might miss them if you read only the first page |
| Owns 10 percent and appoints the directors | Control | You would exclude them, wrongly, if you stop at 25 |
| Owns 8 percent, no control | Neither, on these facts | You might add them only because they attended the meeting |
Where the two-limb page stops
This page is the pair of limbs. It is not the full definition, and it is not a worked chain of shareholdings. The definition is what is a beneficial owner?, and direct and indirect shares are beneficial owner of shares.
FreeAML does not calculate the percentage and does not decide control. The firm records both limbs itself.
What the client pays
On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. A person added on control is still their own KYC check, not a free extra on the ownership calculation. Confirm the live amounts on FreeAML pricing. FreeAML does not apply the 25 percent test or the control test to a customer.
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Frequently Asked Questions
Verify each person either limb names.
The firm suite is A$0. The client pays. KYB for the company or trust. KYC for each individual.
Start an AML checkQuestions: team@freeaml.com.au