This memo covers investments in collective investment vehicles (CIV) in contractual, trust, or corporate form (simply referred as funds) from corporate and institutional investors acting on their own account (e.g. banks, life insurers, industry companies, etc.) and the accounting treatment of such investments under the upcoming IRFS 9 rules. While IFRS 9 contains many positive evolutions, many of our members have been warned by their client investors that IFRS 9 would change their attitude towards investing in funds.

EFAMA is grateful for the opportunity to comment on the OECD Public Discussion Draft related to concerns received by the OECD on previous discussion drafts related to the Report on Action 6, as to how the new provisions included in the Report on Action 6 could affect the treaty-entitlement of nonCIVs. We agree with the aim of the discussion draft to clarify any concerns in relation to the discussion concerning the treaty entitlement of CIVs / Non-CIVs.

EFAMA fully supports the aim of eliminating tax abuse enshrined in the draft Anti-Tax Avoidance (ATA) Directive which the European Commission published on 28 January 2016. EFAMA is the representative association for the European investment management industry. EFAMA represents through its 26 member associations and 61 corporate members EUR 21 trillion in assets under management of which EUR 12.6 trillion managed by 56,000 investment funds at end 2015.