The publication shall always take place on behalf of the direct or indirect beneficiary of the granted benefit (Art. 41, §2, Sunshine Act), taking into account the following (see Art. 3, clause 1, 4°, RD Sunshine Act):
- regarding fees, payments and reimbursement of costs for services and consultancy to healthcare organisations, the beneficiary is the latter, except if it concerns a healthcare professional who acts as a company or who is part of a de facto association, in which case the beneficiary is the healthcare professional who provided the services that led to the fees and payments;
- regarding contributions to the costs of participation in scientific events, the beneficiary is the healthcare professional who has actually participated in the scientific event even if the healthcare professional has received this premium or benefit through a healthcare organisation;
- regarding contributions to the costs of organising scientific events, the beneficiary shall be the healthcare organisation or the patient organisation that received the contributions.