In this consultation response, which is part of our ongoing efforts on seeking clarification on the application of SFDR, we have stressed the importance of ensuring coherence and alignment between different levels of reporting under EU law and asked the European regulators to introduce an element of proportionality into the reporting of Taxonomy alignment by asset managers.
In this response we reminded the European Commission about the importance of making changes to the investor categorisation, we explained the relevance of the ELTIF framework and we provided our support to rules that appropriately take into consideration both the nature of investors and of the funds that are marketed to them.
In this response, we have shared our views on the European Commission’s initiative to review the VAT rules for financial services. We stressed that the European Commission must preserve and strengthen the VAT exemption for fund management, as it is essential for EU based private equity funds, and the EU economy and EU businesses depending on their investments.
In our response to the European Commission feasibility assessment on the establishment of an SME Referral Scheme we express our concerns around the functioning and benefits of such a scheme. We outline the characteristics that make PE and VC funding different to justify why this type of funding is not interchangeable with bank financing and why we fear the scheme could give this mistaken idea to SMEs. Therefore, even though we fully support the objectives of increasing funding options and awareness of PE and VC funding for SMEs we do not believe a referral scheme would be the best way to do so.
In this response, we have stressed that funds and fund managers should not be included in the scope of a potential digital levy proposal, and that a potential EU proposal should be consistent with OECD work and not be pushed forward while work is still ongoing on OECD proposals.
As investors in innovative and high-growth companies and start-ups, we find it crucial that a tax regime for the 21st century encourages and supports the innovation and research needed for the green and digital transition and the recovery of the European economy after the COVID-19 crisis.
In this response, we have shared our views on the European Commission’s initiative to increase convergence of national insolvency laws to encourage cross-border investment. From an investors’ perspective, we believe that harmonised rules offer transparency and clarity across the EU market and should be the goal in the long term.
As the Foreign Direct Investment (FDI) screening landscape across Europe is rapidly evolving, Invest Europe has prepared a country-by-country overview to map different existing regimes and keep-track of latest developments with view to helping members assess how FDI screenings may impact their transactions.
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.
Guidelines on sound variable remuneration will apply to all MiFID investment firms, although some rules will be waived below a defined threshold. In this response we reiterate the importance of protecting the carried interest model while flagging some technical concerns we have with some sections of the Guidelines, including on the definition of the thresholds.
Public Affairs Director
Senior Public Affairs Manager
Public Affairs Officer
Sofia Garrido Perez
Public Affairs Officer
Public Affairs Manager
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