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Response to HLEG consultation on its interim report on Sustainable Finance Image

Response to HLEG consultation on its interim report on Sustainable Finance

In this response Invest Europe has expressed its support for the work of the High Level Expert Group, highlighting the important role that private equity can play in the achievement of the EU’s goals on sustainable finance and development. In addition, we emphasised the need to take account of existing international classification systems, labels and standards and expressed our concerns about the implications this work-stream may have on certain parts of financial services legislation.

Positions & consultation responses

20 Sep 2017
Response to Commission Consultation on "Reducing barriers to cross-border distribution of investment funds” Image

Response to Commission Consultation on "Reducing barriers to cross-border distribution of investment funds”

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.

Positions & consultation responses

14 Jul 2017
Response to Commission Consultation on the review of the SME definition Image

Response to Commission Consultation on the review of the SME definition

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.

Positions & consultation responses

06 Jul 2017
AIFMD Essentials 2017 Image

Member Only

AIFMD Essentials 2017

This member guide to the AIFMD explains its key provisions and implementing measures from a private equity perspective. It sets out the requirements for general partners and covers the impact on investors and funds of funds.

Member guides

24 May 2017
Response to EIOPA Call for Evidence on Solvency II treatment of unlisted equity and debt Image

Response to EIOPA Call for Evidence on Solvency II treatment of unlisted equity and debt

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.

Positions & consultation responses

24 May 2017
Response to European Supervisory Authorities Review Consultation Image

Response to European Supervisory Authorities Review Consultation

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.

Positions & consultation responses

16 May 2017
The Use of Holding Companies and Choice of Jurisdictions by the Private Equity Industry Image

The Use of Holding Companies and Choice of Jurisdictions by the Private Equity Industry

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.

Member guides

04 May 2017
Response to Commission Consultation on prudential treatment of investment firms Image

Response to Commission Consultation on prudential treatment of investment firms

In this response to the Commission Inception Impact Assessment on its future proposal on the prudential treatment of investment firms, Invest Europe supports the principle of establishing a prudential regime better tailored to investment firms but details its concerns over a proposal that would not take into account the specificities of the private equity industry

Positions & consultation responses

19 Apr 2017
Response to Capital Markets Union Mid-Term Consultation Image

Response to Capital Markets Union Mid-Term Consultation

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.

Positions & consultation responses

17 Mar 2017
Position Paper on Insolvency Directive Image

Position Paper on Insolvency Directive

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.

Positions & consultation responses

16 Mar 2017
Response to EBA Discussion Paper on the prudential treatment of investment firms Image

Response to EBA Discussion Paper on the prudential treatment of investment firms

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.

Positions & consultation responses

06 Feb 2017
Joint Letter Invest Europe/AIC on OECD BEPS Action 6 Image

Joint Letter Invest Europe/AIC on OECD BEPS Action 6

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.

Positions & consultation responses

03 Feb 2017
Response to ECB Guidance on leveraged transactions Image

Response to ECB Guidance on leveraged transactions

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.

Positions & consultation responses

27 Jan 2017
Response to Commission Questionnaire on EU Merger Control Image

Response to Commission Questionnaire on EU Merger Control

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

Positions & consultation responses

13 Jan 2017
Paper on the main barriers to the cross-border distribution of funds Image

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

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.

Positions & consultation responses

30 Nov 2016