PensionsEurope provides feedback to the European Commission Proposal for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes

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. 

PensionsEurope input to the EC consultation on the review of the central clearing framework in the EU

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 Russian aggression and calls for effective implementation of EU sanctions

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. 

PensionsEurope comments on EBA consultation EMIR rules on Initial Margin Model Validation

PensionsEurope welcomes the opportunity to comment on the EBA consultation about its draft Regulatory Technical Standards (RTS) on Initial Margin Model Validation (IMMV) under the European Markets Infrastructure Regulation (EMIR). It is PensionsEurope’s opinion that the suggested RTS regarding the adoption and governance of IM models will introduce new heavy and unjustified burdens on a vast number of counterparties and we believe that the proposed requirements overshoot what’s necessary in order to curb risks to the financial system arising from IM calculations.

We therefore suggest removing the article 2, 2. option or, at least, to provide clearer and more objective criteria for requiring section 3 compliance from counterparties above the EUR 50 billion threshold. You can read our comments here.

PE comments on IFRS consultation on developing disclosure requirements and proposed amendments to IFRS 13 and IAS 19

PensionsEurope welcomes the opportunity to comment on the IFRS consultation regarding the developing disclosure requirements and proposed amendments to IFRS 13 and IAS 19. PensionsEurope believes that the note disclosures with regards to pension plans are already very comprehensive in current annual financial statements. Most of the information disclosed in the notes already covers the proposed disclosure objectives. For this reason, it is unclear how the new concept should better meet the users' needs.  Furthermore, PensionsEurope believes that any structured disclosure process needs checklists to decide which information will not be provided due to materiality reasons. Therefore, a checklist approach has its advantages You can read our answer and explanation here.

PensionsEurope: PRIIPs KID is not suitable for pensions products

On 16 December 2021 PensionsEurope answered to the ESAs’  Call for evidence on the European Commission mandate regarding the PRIIPs Regulation advocating that the scope of the PRIIPs Regulation should not be extended to pension products. You can read our answer and explanation here.

PensionsEurope webinar Investing in the future during European Retirement Week

On 1 December 2021, PensionsEurope hosted its webinar Investing in the Future as part of the inaugural European Retirement Week (29 November - 3 December), an initiative by 11 European associations to provide a platform for a wide range of stakeholders to debate the future of pensions in Europe and to raise citizens’ awareness of the need to save for retirement. Pension adequacy is crucial to address Europe's savings gap and one of the first steps to achieve this is to raise public awareness of the need for long-term savings and returns.
During the seminar, PensionsEurope built on its programme "Investing in the Future", that was created earlier this year and launched at the PensionsEurope annual conference 2021, and stimulated the debate on pension oppoortunities and planning, alternative investments and the challenges and trends for 2021 and beyond. In a second session, we learnt more about Pension Tracking Services (PTS) and Dashboards, with EIOPA sharing how these could be developed and a case study on PTS from Sweden, followed by a panel discussion.

The webinar is available here; the full programme here.

PensionsEurope welcomes Insurance & Pension Denmark as a new member

Today, the PensionsEurope Board of Directors accepted Insurance & Pension Denmark as its newest member. Insurance & Pension Denmark is the trade association of insurance and pension companies in Denmark. They represent about 80 insurance and pension funds in the Danish market and play an important role in solving the challenges of the welfare state by supplementing public welfare provisions. The Danish pension funds hold more than € 500 billion in investments in Denmark and abroad. Read more in our press release here.

PensionsEurope feedback to the Commission on its WHT roadmap

In its feedback to the European commission, PensionsEurope welcomes the Commission’s roadmap on the new EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes (WHT). We support the current Commission´s mandate call for removing all barriers to the completion of the Capital Markets Union (CMU) –  particularly in the field of simplifying taxation.

PensionsEurope agrees with the objective that a standardised relief at source system becomes the principal mechanism for WHT relief procedures and their streamlining. We have stressed for a long time that the relief at source is the best practice for pension funds. We warmly welcome the action of the Commission ‘Action Plan for fair and simple taxation supporting the recovery strategy’ to introduce a common, standardised EU-wide system for withholding tax relief at source.

However, there are also many other recent WHT proposals which the EC should thoroughly consider. PensionsEurope has proposed to the Commission to establish an EU tax register of recognised pension institutions in order that Member States can reciprocally and automatically recognise pension institutions. Furthermore, in many countries pension institutions invest cross border via specialised investments funds and/or vehicles to increase the economies of scale, and it is important to ensure a tax-neutral treatment of these investment structures as well.

PensionsEurope letter to Commissioner McGuinness on PSAs clearing with the UK CCPs

Today, PensionsEurope sent a letter to Commissioner Mairead McGuinness on pension scheme arrangements' (PSAs) clearing with the UK CCPs. In that letter, PensionsEurope requested the Commission to grant one year extension to the current equivalence decision in relation to UK CCPs. In exchange, PSAs are willing to continue actively reducing their exposures to UK CCPs, and open and hold active accounts within the EU based CCPs. You can read the letter here.