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Associação Portuguesa de Fundos de Investimento, Pensões e Patrimónios

APFIPP

A APFIPP é uma Associação sem fins lucrativos que tem por objecto a representação e a defesa dos interesses das suas Associadas, contribuindo, designadamente, para a promoção e desenvolvimento das Indústrias de Fundos de Investimento Mobiliário, de Fundos de Investimento Imobiliário, de Fundos de Pensões e de Gestão Discricionária portuguesas, e do espaço único europeu, onde as mesmas operam profissionalmente, enquanto Entidades Gestoras de Activos e de Fundos de Pensões, de harmonia com a legislação nacional e comunitária aplicável.

Lobbying Activity

Response to Recommendation on savings and investment accounts

7 Jul 2025

APFIPP welcomes the opportunity to contribute to the European Commissions work on the creation of a European blueprint for Savings and Investment Accounts (SIAs), which will be accompanied, as foreseen in the Savings and Investment Union Communication (published on 19th of March 2025), by a recommendation addressed to Member States on the tax treatment of those accounts. We support this initiative as it promotes retail participation in Capital Markets, in alternative to traditional bank deposits, which typically offer limited returns. By channelling household savings to those investments, such initiative not only empower individuals to build long-term financial resilience but also contribute meaningfully to broader economic development and innovation across the European Union. In our opinion, the success of this initiative will depend on the establishment of a coherent and investor-friendly framework across Member States that should address several topics, namely regarding the following three pillars: 1. A favourable tax regime: Experience from several Member States shows that fiscal incentives - such as exemptions or reduced rates - are decisive in encouraging retail investor uptake. The Commission notes that the most successful schemes are those offering preferential tax treatment; 2. Simplified tax compliance procedures: Reducing the complexity and administrative burden associated with reporting investment income and capital gains is equally critical. The adoption of simplified procedures - such as withholding at source or automatic reporting - can remove barriers to participation and increase investor confidence 3. A single rule on cost transparency: Harmonised criteria for disclosing fees and charges associated with SIAs are essential to ensure comparability between offerings and to foster competition among financial service providers. In this context, it is recommended that the Commissions proposal ensure the adoption of these three foundational elements, alongside the additional considerations highlighted in the attached file. Only then can SIAs become a true instrument of financial inclusion, mobilising citizens savings to finance the European economy and contributing to the deepening of the Capital Markets Union.
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Response to Retail Investment Package

28 Aug 2023

APFIPP is the Portuguese Association of Investment Funds, Pension Funds and Asset Management, representing the interests of Portuguese Asset Managers (UCITS and AIF Management Companies and Investment Firms performing Portfolio Management) and Pension Funds Managers. APFIPP has been following the developments of the European Commission Capital Markets Union Action Plan (CMU), since it was first announced in September 2020, and the definition of a strategy to increase the participation of retail investors in capital markets (Retail Investment Strategy - RIS), in line with the priorities it has set for the years 2019 to 2024 and, in particular, with the objective of creating "An economy that works for people" that originated the European Commissions Proposal for a Directive of the European Parliament and of the Council, amending Directives (EU) 2009/65/EC, 2009/138/EC, 2011/61/EU, 2014/65/EU and (EU) 2016/97 as regards the Union retail investor protection rules published last May. Although APFIPP supports the main goals of the RIS, it is essential to draw the attention of the Commission to the need of ensuring that certain distribution models of Collective Investment Undertakings (CIUs), that are common to several Member States, are maintained. APFIPP is especially concerned with the insertion of the new article 24a Inducements into Directive 2014/65/EU (MIFID) and the partial ban of inducements that is proposed. In APFIPPs opinion, this is a matter that must be properly considered, since it could have negative and undesirable effects, both on Asset Management Companies and in CIUs unit-holders. In view of the above, APFIPP presents, in the document attached, some key aspects concerning the subject, with the expectation that it may contribute for the discussion and analysis of this important topic to the Industry. APFIPP appreciates the attention given to this matter and remains at your disposal for any further information, looking forward to continuing to work with the competent authorities on advancing the capital markets in Europe.
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