Position papers, statements and consultation responses

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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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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.

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Joint response to FSB Consultation on structural vulnerabilities of asset management activities

21 September 2016, Invest Europe- PAE

This joint response, with the American Investment Council, outlines why private equity firms and funds do not give rise to policy concerns regarding asset management activities, in particular when it comes to leverage and organisational requirements.

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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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