Invest Europe

Invest Europe is the trade association representing private equity (PE), venture capital (VC), and infrastructure fund managers, as well as their investors, across Europe. Our members are mostly small and mid sized management companies that play a key role in financing innovative and growing European businesses.

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.

At times where public funding is by nature a scarce commodity, we advocate for the EU budget to focus on mobilisation of additional private investments. The onus should be on areas where public intervention can incentivise private investors to commit capital to long-term EU projects that have a high impact value for the EU economy.

The European Commissions efforts to simplify the ESRS are very welcome. In particular, the acknowledgement in the Delegated Act that businesses carrying out asset management activities should not be required to report information that is not relevant in relation to the investments they manage, as well as the clarification (application requirements (ARs) 17 and 37) that entities managing investments under fiduciary…

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.

Invest Europe supports the Commission’s (EC) work to ensure that material sustainability factors are assessed, consistently taken into account and disclosed by institutional investors and asset managers. However, it is crucial that an accepted definition of “sustainability” (eg Brundtland report) is used and the scope captures all aspects of sustainability (climate change, environment, social & governance).

Invest Europe welcomes the CSRD proposal. As a data driven industry, we support the view that to achieve sustainable and inclusive growth it is key to have relevant, comparable and reliable sustainability information as a pre-requisite for tracking progress and, ultimately, meeting the EU sustainability targets.

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.

We respond on behalf of the European private equity industry. While typically private equity funds are not offered to retail investors, some managers have recently set up structures that allow investors that are neither professional nor sophisticated to access the asset class. This is for example the case of managers setting up “ELTIF” vehicles.

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 European Commissions proposal of the Directive on Faster and Safer Relief of Excess Withholding Taxes and the initiative to introduce a common EU-wide system for withholding tax on dividend or interest payments, as we encourage the idea of removing tax barriers to cross-border investment.

Invest Europe welcomes the European Commission’s initiative to investigate a common EU-wide system for withholding tax on dividend or interest payments, as we encourage the idea of removing tax barriers to cross-border investment.

Invest Europe commends the Commission for making efforts to increase investments in European businesses. Balancing the treatment of debt and equity financing in a more equitable way is a daunting task and whilst addressing a perceived “bias” seems logical, it is worth noting there are many valid legal, regulatory and commercial reasons for use of debt.

Invest Europe welcomes the European Commission’s initiative to look into possible options to mitigate a potential debt-equity bias induced by taxation, and would like to share the following points, which we believe are important to take into account when designing such a system.

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 welcomes the European Commissions proposal to further harmonise the insolvency law and procedure across the Member States. We fully support the principles behind the proposal, in particular the intention of shorter, more efficient and less court-led insolvency process.

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).

Invest Europe is pleased to see that the European Commission’s proposal on a minimum level of taxation for large multinational groups closely follows the OECD Model Rules for Pillar Two. When taxing companies which are part of global value chains, the global aspects must be taken into account.

Invest Europe supports the European Commission’s objective to develop a coherent regulatory framework to empower consumers to make informed investments in EU capital markets. Traditionally, the private equity industry is only marketing to investors that are either institutional (pension funds, insurers, banks, sovereign wealth funds, fund-of-funds) or at the very least experienced (family offices, entrepreneurs).

The private equity industry welcomes the European Commission's initiative to assess the relevance of the current VAT rules for financial and insurance services, notably in the light of developments in the sectors and recent case law challenging practices allowed by most Member States.