Position papers, statements and consultation responses
Find relevant Invest Europe consultation responses and position statements as well as EU and international institutions' proposals, statements and position statements.
Response to Commission consultation on the cross-border distribution of funds
10 October 2016, Invest Europe-PAE
This PAE response to a European Commission Consultation outlines the main barriers faced by private equity and venture capital fund managers when marketing their funds cross-border. The response focuses in particular on marketing requirements, costs, regulatory fees and taxation barriers. The consultation is part of the Commission's efforts to build a Capital Markets Union in Europe.
Response to European Commission Consultation on EU Insolvency frameworks
15 June 2016, Invest Europe
In this response Invest Europe reiterated its concerns about plans to fully harmonise insolvency frameworks across the EU. Rather than being considered barriers to the functioning of the EU internal market, differences between existing national regimes should be seen as offering a greater variety of options for debtors who operate across borders.
Response to EIOPA's Consultation on the treatment of infrastructure corporates under Solvency II
13 May 2016, Invest Europe
The response welcomes EIOPA’s amendments to the definition of ‘infrastructure projects’ and to the relevant qualifying criteria that intend to capture certain type of infrastructure corporates. It stresses however that the proposed definition of ‘infrastructure corporates’ is overly restrictive and might exclude infrastructure corporates that represent suitable infrastructure businesses. It also lies out concerns about EIOPA’s proposal to calibrate capital requirements for infrastructure corporates based on available market data.
Response to OECD Consultation on Treaty Entitlement of non-CIV Funds (BEPS Action Point 6)
22 April 2016, PAE-Invest Europe
With this paper, we responded to all consultations the OECD put forward on BEPS Action Point 6 on Treaty Abuse. Our response explains how private equity funds are not in the business of treaty shopping and suggests a solution based on an investor self-certification approach.
Response to Commission Consultation on EU Transparency Register
17 April 2016, Invest Europe
The EU Transparency Register requires that associations such as Invest Europe give detailed information on the structure of their organisations ahead of their engagement with the European Parliament and the European Commission. The consultation seeks the opinion of stakeholders on future changes to the existing regime. Invest Europe took this opportunity to share its views on the role of transparency in good and efficient law-making.
Position Paper on Prospectus Regulation
1 April 2016, Invest Europe
This Position Paper sets out our views on the Commission Proposal for a Prospectus Regulation. This Paper mainly addresses the scope of the Prospectus, the exemption for "sophisticated investors" and the widening of the SME regime to growth companies.
Response to ESMA Consultation on Guidelines on market soundings (Market Abuse Regulation)
31 March 2016, Invest Europe-PAE
The PAE responded to this consultation to stress that, because private equity firms are rarely recipients of makes market soundings due to the nature of our industry, some of the draft Guidelines may be unnecessarily prescriptive and onerous for them. This responses suggests to ESMA the appropriate level of flexibility in the Guidelines to address this issue.
Response to Commission Consultation on Long-Term and Sustainable Investment
25 March 2016, Invest Europe
In this response to DG Justice, Invest Europe welcomes and supports the European Commission’s priority to foster sustainable investments. The document flags the long-term nature of private equity investments and underlines the principles the members of the association have set in the Professional Standards Handbook to promote highest ethical and professional standards within the industry.
Response to BCBS Consultation on Step-In Risk
17 March 2016, Invest Europe-PAE
In order to ensure that banks will continue to be able to provide necessary services to the private equity industry, the PAE encourages the Basel Committee (BCBS) to review its proposed approach, and in particular the definition of “sponsor”, to avoid capturing bank activities that it believes do not entail any step-in risk. This risk mainly stems from the ambiguity over the concepts of ‘credit enhancement’ and ‘placing securities into the market’.
Position Paper on the European Commission Anti-Tax Avoidance Package
16 March 2016, Invest Europe-PAE