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 "Reducing barriers to cross-border distribution of investment funds”
14 July 2017, Invest Europe-PAE
In this response Invest Europe welcomes the Commission’s potential initiative to reduce national regulatory barriers to the cross-border distribution of investment funds and agrees with the identified policy areas, such as the definition of marketing or regulatory fees currently imposed on fund managers.
Response to Commission Consultation on the review of the SME definition
6 July 2017, Invest Europe-PAE
This response to this Commission Inception Impact Assessment welcomes the Commission consideration to revise the SME definition and suggests this revision should make clear that firms backed by private equity and venture capital investors do not, solely by virtue of that ownership form, fall outside the definition of an SME.
AIFMD Essentials 2017
24 May 2017, Invest Europe
This member guide to the AIFMD, explains its key provisions and implementing measures from a private equity perspective. It sets out the requirements for GPs and covers the impact on investors and fund-of-funds.
Response to EIOPA Call for Evidence on Solvency II treatment of unlisted equity and debt
24 May 2017, Invest Europe-PAE
This response summarises the private equity industry’s position on the criteria that could be used to identify unlisted equity to which a lower risk charge could be applied. It also reiterates our concerns that existing Solvency II capital charges does not reflect the actual risk insurers face when investing in the asset class and argues that it should be significantly lower than the existing 39%. The Call for Evidence is part of the technical work undertaken by EIOPA to advise the European Commission on the reassessment of the risk-weighting for insurers' investments into unlisted equity and debt as part of their Solvency II review in 2018.
Response to European Supervisory Authorities Review Consultation
16 May 2017, Invest Europe-PAE
The PAE response to this Commission Consultation details the views of the private equity industry on potential changes made to the European Supervisory Authorities (ESAs) structure, governance and funding, in particular the suggestion for the ESAs (which include ESMA, EIOPA and EBA) to be funded directly by industry participants.
The Use of Holding Companies and Choice of Jurisdictions by the Private Equity Industry
4 May 2017, Invest Europe
With the OECD work on Base Erosion & Profit Shifting (BEPS) now nearing its completion, and with various new tax rules having being agreed at EU level to increase transparency, significant reform has been brought about in the tax domain. At Invest Europe, we have contributed to numerous consultations and proposals to ensure that any new rules do not have unintended consequences. This short note brings together our common messaging on tax issues concisely explaining why private equity funds use structures such as holding companies and invest via certain jurisdictions.
Response to Capital Markets Union Mid-Term Consultation
17 March 2017, Invest Europe- PAE
This consultation response details what additional actions Invest Europe would like the Commission to take to improve the state of European capital markets. The main focus is put on the improvement of the existing passporting framework (whether through the EuVECA review or limitations to existing fees and charges) and ways to allow an easier access to the asset class for institutional and sophisticated investors.
Position Paper on Insolvency Directive
16 March 2017, Invest Europe- PAE
This Position Paper outlines our reaction to the Commission Proposal for a Directive on preventive restructuring frameworks (the Insolvency Directive) in which we welcome the proposed new rules and outline suggestions for how the proposed Directive could be improved in several areas.
Response to EBA Discussion Paper on the prudential treatment of investment firms
6 February 2017, Invest Europe- PAE
The PAE responded to this Discussion Paper of the European Banking Authority, stressing that the approach taken by the EBA failed to recognise the prudential risk posed by private equity managers and advisers when they conduct MiFID activities and could significantly raise the capital and liquidity requirements they are currently subject to under CRR.
Joint Letter Invest Europe/AIC on OECD BEPS Action 6
3 February 2017, Invest Europe-AIC