On 6 April 2022, PensionsEurope commented on the European Commission Proposal for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU. In our feedback,  we supported the aim of preventing the use of legal entities and arrangements without minimal substance for tax avoidance or tax evasion purposes, and suggested certain adjustments to the European Commission’s proposal that we consider necessary to ensure that pension funds and the investment structures they use do not incorrectly fall within the scope and be impacted unintendedly. 

In its input to the European Commission, PensionsEurope welcomes the review of the central clearing framework in the EU.

For the challenges related to Pension Scheme Arrangements’ (PSAs) upcoming clearing obligation, the best way forward is a structural solution, involving central bank liquidity, as central clearing houses in Europe would suffice to provide (indirect) central bank liquidity utilizing their cleared repo platform. Therefore, PensionsEurope proposes to the Commission that the solution would be that the European central clearing houses could provide central bank liquidity to PSAs in times of stress to convert high quality government bonds into cash.

PensionsEurope agrees with the recent ESMA advice to the Commission that an extension of PSAs’ exemption from clearing obligation until 19 June 2023 is still needed.

PensionsEurope condemns in the most severe terms the unlawful aggression of Russia against Ukraine and the people of Ukraine. It is imperative that the economic sanctions against Russia are effectively implemented. Many pension funds have already decided to divest from Russia. We call upon our members and all pension funds in Europe to contribute to their best that economic sanctions of the European Union against Russia are effectively implemented, and pension fund investments will not enable Russia to continue its invasion of Ukraine.