In our input to the European Commission, PensionsEurope supports the Commission’s objective to simplify the life of taxpayers operating in the single market and we welcome the review of the VAT rules. In general, we believe all pension fund participants should be protected from unnecessary VAT burdens, regardless the character of the schemes as well as the Member State in which the services are being received. The current exemption for special investment funds should be extended to all pension schemes.

Even though the VAT exemption is in place, in some countries there is a stamp duty (for instance 4%) that is not subject or exempt from VAT and there is no possibility of any deduction. We urge the EC to recommend Member States to exempt (at least) pension schemes from this duty (or decrease their duty to no more than 1%).

Finally, we believe that establishing a cross-border investment-friendly tax environment in the EU not only requires removing unfair tax treatment but also introducing tax incentives.

In a press release issued today, PensionsEurope corrects the conclusions from Better Finance on the Bulgarian pension funds. Making use of incorrect data, Better Finance declares that Bulgarian private pensions have failed and goes as far as to recommend reversing the private pension reform of 2000 which means nationalising individual pension savings in Bulgaria. Not only would this have a detrimental effect on Bulgarian pensions, it also strongly contradicts with numerous European policy recommendations that highlight the importance of strengthening supplementary pensions in order for all Europeans to have adequate and sustainable income in old age. Read more in our press release.

PensionsEurope submitted its response to the ESAs’ survey on their mandatory templates of pre-contractual and periodic disclosures for products that “promote” ESG characteristics and products with sustainability objectives (articles 8, 11 and 9 of the Sustainable Finance Disclosure Regulation, SFDR).

In its response, PensionsEurope emphasises that a highly standardised presentation of the information in product disclosures is undesirable as the templates seem to be designed for classic investment products and are therefore not adequate for most pension plans. The proposed draft RTS and templates do not provide any differentiation between the various types of financial products, although SFDR requires the ESAs’ to take account of  the various types of products and their characteristics when designing the new disclosure requirements and templates. 

The response also draws attention to the need to simplify the templates and rejects the graphical representations proposed in the illustrative mock-ups as they would not adequately reflect IORPs’ investment strategies and would therefore be somehow misleading.

You can read our response to the ESAs' survey here.