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The Call for Evidence does not provide sufficient detail on the magnitude of the problems identified or the concrete proposals under consideration. Respondents are asked to consider the impact of policy initiatives, but the initiatives and policy direction under consideration are unclear, making it difficult to provide meaningful feedback.

The ACA wishes to express its concern about the impact of these texts on our members. The multiple bans proposed, the many additional requirements will complicate consumers’ access to capital markets considerably, which is the exact opposite of what the European Commission is seeking to achieve with the IPM.

Filed in French · English published by the European Commission

Insurance Europe supports the goal of the Retail Investment Strategy (RIS) to increase retail participation in financial markets, while protecting investors from unfair practices. Within a well-designed legislative framework, insurance-based investment products (IBIPs) are key to enabling consumers to invest with confidence in capital markets, access insurance protection and prepare for old age.

Insurance Europe welcomes the possibility to comment on this roadmap. Provisions around withholding tax procedures for cross-border portfolio investors or shareholders in the EU, which are different between member states, often pose a challenge to insurers in regard to cross-border investment, due to their complexity and the related costs.

ACA welcomes the possibility to comment on this roadmap. As other actors, we believe that cross-border investment and simplified taxation should be a priority for the EU and that tax barriers to cross-border investment should be removed. However, nowadays, too often, the process to claim a refund looks more like an obstacle course than a legitimate right.