Invest Europe

Europe's private equity and venture capital (PE/VC) ecosystem has reached scale, with deep venture, growth and buyout markets operating increasingly across borders. However, following its fundraising and investments peaks, it is now recovering unevenly across stages.

Europe has world class scientific excellence in biotech and healthcare, yet it underperforms in translating this strength into globally competitive companies, industrial capacity and patient access. Public capital is retreating from biotech and healthcare faster than from the wider PE/VC market, while institutional investors remain underrepresented in the sector, limiting long-term, stable capital.

At Invest Europe the association representing Europes private equity, venture capital (PE/VC) and infrastructure sectors, including fund managers and investors in biotech and life sciences our members are committed to unlocking the potential of competitive sectors, including biotech. Yet, persistent structural barriers are limiting progress and competitiveness.

On behalf of the pan-European private equity and venture capital (PE/VC) industry, weve set out below our comments on the future direction of SFDR. The attached comprehensive response contains further technical details and supporting arguments. Please also refer to our previous letters to the Commission from 30/01 and 16/05/2025.

The business and economic case for climate resilience has never been stronger. Resilience is not separate from business and economic interests; it is where asset protection, market stability, and growth opportunities intersect. Beyond weathering storms, resilience ensures functional markets, protects investments, and unlocks growth in an economy where climate volatility is the new normal.

Invest Europe welcomes the European Commissions initiative to simplify EU rules on direct taxation through an Omnibus package. While recent EU tax initiatives have pursued important policy objectives, their cumulative impact, combined with divergent national implementation, has created significant legal uncertainty and administrative burdens.

Invest Europe is the worlds largest association of private capital providers. We represent Europes private equity, venture capital and infrastructure investment firms, as well as their investors. Our association has a global presence, with more than 650 members covering 57 countries, where a big part of them works on more than one European market.

Invest Europe takes note of the European Commission's proposal for a directive on transfer pricing. However, we may not see an immediate necessity for this directive, given the existing comprehensive guidance provided by the OECD through its Transfer Pricing Guidelines.

Invest Europe welcomes the European Commission's proposal for a directive establishing a Head Office Tax system for micro, small, and medium-sized enterprises (SMEs) as a significant development that holds the potential to simplify and harmonize tax compliance for qualifying businesses operating across European borders.

Invest Europe welcomes the opportunity to contribute to the evaluation and recast of the EU Directive on Administrative Cooperation in taxation (DAC), with a particular focus on DAC6 and the potential integration of the Unshell Directive (ATAD3) into a simplified framework.

Invest Europe would welcome the opportunity to highlight some key points on the operation of the 'investment fund' exemption (which limits the FSR reporting obligations to the funds involved in the transaction).