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 welcomes EIOPA’s consultation and the opportunity to share our views on EIOPA’s recommendations to develop an EU single market for personal pensions.

EFAMA supports the conclusions of EIOPA’s impact assessment:

• The standardization of key elements of a PEPP - as proposed by EIOPA in its advice - with space to accommodate the specificities of Member States, is the best policy option.

• It would be difficult to achieve full standardization via harmonization because this would require bringing all national regulations on PPPs to one level.

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.