Position papers, statements and consultation responses

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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.

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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.

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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.

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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.

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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. 

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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.

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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’.

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Position Paper on the European Commission Anti-Tax Avoidance Package

16 March 2016, Invest Europe-PAE

This Position Paper sets out our views on the Commission Proposal for an Anti-Tax Avoidance Directive (ATAD). This Paper mainly addresses the question of interest deductibility and the importance of not increasing the cost of financing for the real economy. 

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Response to European Commission Call for Evidence on EU Regulatory Framework for Financial Services

31 January 2016, PAE-Invest Europe

This PAE Response assesses, at the request of the Commission, the combined impact of legislation on our industry and details the situation where existing rules may have a detrimental impact on private equity, venture capital and infrastructure funds without necessarily achieving their proposed objectives. Among the examples given are the absence of a passport for sub-threshold funds and the regulatory treatment of semi-professional investors.

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Response to ESAs Consultation Paper on KID-PRIIPS draft regulatory technical standards

29 January 2016, PAE-Invest Europe

This PAE response comments on the proposed approach taken by the ESAs to determine the Single Risk Indicator and the costs contained in the Key Information Document ("KID"). It argues that the level of risk assigned to private equity is not based on actual data and that carried interest should not be considered as a cost due to its inherent characteristics. 

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