The Commission launched a public consultation ahead of the presentation of a legislative proposal to introduce an EU Digital Levy by January 2023. For EFAMA, any new tax legislation on “digital activities” (or “digital transactions”) should not be borne by the end-investors. Our understanding is that the industry’s activities should not be in scope of the new tax. 

The fund and asset management industry is a highly regulated industry operating under significant and specific legal, regulatory, transfer pricing and tax frameworks. 

Pillar 1: Investment funds are structured as tax neutral investment pooling vehicles as a matter of
public policy.

Pillar 2: The role that investment funds play in providing investors with a diversified portfolio and global market access is essential.

EFAMA comments the IASB's Exposure Draft (ED/2017/7). It supports IASB's efforts to improve consistency in the layout of the primary financial statements and the relevance of financial statements.

Proposals around new defined sub-totals and line items will improve consistency and will assist in the implementation of electronic reporting format initiatives.