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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.
Positions & consultation responses
The Invest Europe Annual Report provides an overview of Invest Europe's activities during the 12 months to June 2016 in fields including public affairs, data & research, events and communications. The report includes a financial statement.
Other publications
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.
Positions & consultation responses
Member Only
University of Oxford, American University of Sharjah, Frankfurt School of Finance & Management" “In private equity, General Partners (GPs) may receive fee payments from companies whose board they control. This paper describes the related contracts and shows that these fee payments sum up to $20 billion evenly distributed over the last twenty years, representing over 6% of the equity invested by GPs on behalf of their investors.”
External resources
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.
Positions & consultation responses
This Position Paper sets out our views on the Commission Proposal for a Prospectus Regulation. This Paper mainly addresses the scope of the Prospectus, the exemption for "sophisticated investors" and the widening of the SME regime to growth companies.
Positions & consultation responses
Member Only
Member guides
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.
Positions & consultation responses
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.
Positions & consultation responses
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’.
Positions & consultation responses
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.
Positions & consultation responses
Member guides
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.
Positions & consultation responses
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.
Positions & consultation responses
We responded to the consultation on the re-launch of the Common Consolidated Corporate Tax Base (CCCTB) focusing on the question of the apparent “debt equity bias”. In this paper, we explain that debt and equity are complementary rather than antagonistic and outline why any moves to limit interest deductibility would increase the cost of financing for businesses. We therefore encourage the maintenance of current rules in this area.
Positions & consultation responses