Ann: Cleansing Prospectus, page-128

Substantial holder is someone who has a BENEFICIAL interest in at least 5% of the shares in the company. Therefore, any shares held by another entity for the benefit of the substantial holder are required to be disclosed in the notice. MGI could have a portion of the shares issued to them for the sale of AK to the Queen, the Pope and you, and all of those shares would still form part of their beneficial interest as they'd be held on trust for MGI.