In this new letter to the European Commission, Invest Europe expresses its concerns about the Final Report on SFDR from the European Supervisory Authorities (ESAs). In particular, we refer to the significant new legal risk that certain of the ESAs’ changes create for closed-end funds and ask the Commission to address this before putting forward its legislative proposal to the co-legislators.
12 associations, including Invest Europe, have jointly written to the European Commission expressing their views on the planned initiative to fight the use of shell entities.
Invest Europe, as pan-European representative of the private equity and venture capital industry, commits to actively contribute to the EU becoming climate-neutral by 2050, as set out in the European Green Deal.
We support initiatives to decrease cross-border tax frictions, simplify processes and close abusive practices. However, relevant exemptions must be preserved, in order to ensure tax neutrality of funds.
The long-term equity (LTE) category (Article 171a of Solvency II Delegated Acts) is particularly relevant for exposures to private equity and venture capital funds. As the Solvency II Directive only looks at the equity risk from a volatility angle, this position paper explains why this category is an essential element of the framework and how to make existing criteria more workable.
In this letter Invest Europe congratulates the EBA on its suggestion to only include as shadow banking entities managers of funds that are substantially leveraged - but notes that the EBA's definition of shadow banking entities remains too broad and risks capturing entities that are creating little risk.
In this response, we stress that differences between tax deductions of costs related to debt vs. equity should be dealt with in a way that allows for more deductions – not fewer. Furthermore, we make it clear that companies use debt for a variety of commercial reasons, and in no way solely because of tax deductions.
Invest Europe recognises the announcement of the LP-GP ESG Data Convergence Project which seeks to advance an initial set of ESG metrics and mechanisms for comparative reporting of the private equity industry.
In this letter to the European Commission, Invest Europe expresses the industry's ongoing key concerns about SFDR and its interaction with the Taxonomy Regulation. In particular, we encourage the Commission to address and resolve some of the remaining uncertainties through the revisions which we understand may be contemplated to the draft SFDR Regulatory Technical Standards, due to come into effect on 1 July 2022.
In our response to the survey we identify the current challenges and possible solutions to foster innovation. These solutions, which cover 4 different areas, include the identification and removal of regulatory burdens, the creation of a critical mass for VC in Europe through public support and the creation of the right conditions to strengthen patient capital in Europe, amongst others. We believe the implementation of these actions at pan-European level would contribute to strengthen the European innovation ecosystem for the ultimate benefit of European citizens and economy.
Public Affairs Director
Senior Public Affairs Manager
Public Affairs Officer
Sofia Garrido Perez
Public Affairs Officer
Public Affairs Manager
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