Position papers, statements and consultation responses

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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.

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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. 

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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.

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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.  

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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.

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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. 

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Joint Letter Invest Europe/AIC on OECD BEPS Action 6

3 February 2017, Invest Europe-AIC

The joint response from Invest Europe and the American Investment Council focuses on amendments to the draft examples in the commentary on the Principal Purposes Test (PPT) to be included in the updated Model Tax Convention.

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Response to ECB Guidance on leveraged transactions

27 January 2017, Invest Europe- PAE

This PAE response to a European Commission Consultation outlines the main concerns of the private equity industry with the definition of leveraged transactions, in particular the assumption that a transaction involving a private equity backed company should always be seen as leveraged and the treatment of infrastructure loans.

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Response to Commission Questionnaire on EU Merger Control

13 January 2017, Invest Europe- PAE

This Invest Europe response calls for the determination of simpler thresholds for the EU Merger regime.  

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Paper on the main barriers to the cross-border distribution of funds

30 November 2016, Invest Europe

This paper, based on the response to the Commission Consultation on the cross-border distribution of investment funds, has for objective to summarise the key issues faced by the European private equity industry with the existing passporting framework. 

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