EFAMA commented on IASB’s ED on IAS 12 (Pillar Two Model Rules). As the model rules drafted by the OECD establish that investment funds and investment entities should be carved out / excluded from Pillar Two, at first glance we expect them would not have a significant impact on our industry (at least on the strict product/funds side). While it is still to be confirmed what will be required from asset management firms and investors investing in funds to comply with the new rules, it is clear the analysis is highly complex.
Taxation & Accounting
EFAMA discusses all relevant tax topics with importance to the European asset management industry, such as Tax transparency packages or EU FTT, OECD topics including several actions inserted in the Base Erosion and Profit Shifting (BEPS) project, and all kinds of national developments in case they have an impact on regulated EU investment funds. The focus lays on mainstream funds but we may discuss alternative investment fund tax-related issues, if they are of broad relevance.
IASB ED on IAS 12 – Pillar Two Model Rules
OECD Progress Report "Amount A of Pillar One"
EFAMA welcomes the OECD's work on Schedule C: Exclusion of Revenues and profits from Regulated Financial Services from the scope of Pillar One, in particular the amendments to the definition of “Asset Manager", licensing asset management as a business, the level of regulaton and the activities list.
EFAMA Comments Debt-Equity Bias Reduction Allowance (DEBRA)
EFAMA supports the Commission’s efforts to encourage more companies to finance their investment through equity contributions rather than debt financing.
The Commission decided to follow a policy option that will enable the deductibility of an allowance on equity financing costs complemented by a rule to limit the deductibility of interest on debt financing instruments.
EFAMA replied to the OECD Pillar One – Amount A: Regulated Financial Services Exclusion public consultation
EFAMA replied to the OECD Pillar One – Amount A: Regulated Financial Services Exclusion public consultation. Aiming to change the views of those members of the OECD/IF that still maintain that asset managers should not be excluded from Amount A.
In this comment paper, EFAMA is taking the opportunity to:
EFAMA's comments on EC’s Pillar Two proposal
With the release of this proposal, the Commission is replicating the OECD / BEPS Inclusive Framework (OECD) Pillar Two Global Anti-Base Erosion (GloBE) Model Rules that came live in December 2021 and addresses how Member States will implement them in a coherent and consistent way across the EU. The work of the Commission and the alignment with the work of the OECD / BEPS Inclusive Framework are to be welcomed.
EFAMA's comments on EC’s Un-Shell proposal
EFAMA fully supports the Commission’s initiatives to fight tax avoidance and aggressive tax planning. The work of the technical teams that acknowledged our industry’s special requirements and the proposal of carve-out rules to protect investment structures and end-investors are, to a certain extent, to be welcomed.