Insurance Europe

The insurance industry welcomes the opportunity to provide input to the European Commission for the next evaluation of the General Data Protection Regulation (GDPR) foreseen in 2024. As data processing lies at the very heart of insurers’ business, they are aware of the value of data and the importance of protecting it. Now that the GDPR has been in force for over five years, it has become apparent that work is needed to address problems in some specific areas of the legislation to ensure that the GDPR meets its objectives, which are to safeguard Europeans’ fundamental right to have their privacy and personal data protected and to drive businesses to compete responsibly in the digital world.

…to have their privacy and personal data protected and to drive businesses to compete responsibly in the digital world. Like many other sectors, the insurance industry has invested significant resources in understanding the Regulation and its implications for the sector and to ensure proper implementation of the new regime. At a time when the GDPR has set itself as a global standard, the Commission should consider all possible options to address the text’s shortcomings within the existing legislative framework or to use appropriate complementary measures before considering proposing any amendments to the GDPR.

…framework or to use appropriate complementary measures before considering proposing any amendments to the GDPR. In view of the above considerations, the upcoming evaluation report should assess: • The impact of the GDPR on innovation and address any obstacles the Regulation may have unintentionally created to the development of innovative and emerging technologies such as blockchain, artificial intelligence, big data or the internet of things. These technologies offer great opportunities for insurers and consumers, but innovation in the sector could be undermined if it challenges GDPR provisions and/or EDPB guidelines. • The tools for international data transfer to third countries and suggest ways to address any existing insufficiencies to ensure that European companies can rely on the tools provided in the GDPR and that complying with them is not overly burdensome for firms.

…companies can rely on the tools provided in the GDPR and that complying with them is not overly burdensome for firms. • The role of the European Data Protection Board (EDPB) and the impact of its GDPR guidelines on the EU industry. Guidelines can be useful implementation and compliance tools. However, there are areas, such as international data transfers, right of data access and data breaches, in which the EDPB has not consistently applied the risk-based approach and proportionality principles enshrined in the GDPR as a result of a political agreement at EU level. The EDPB should increase its efforts in terms of transparency and communication.

…of a political agreement at EU level. The EDPB should increase its efforts in terms of transparency and communication. An increased dialogue with stakeholders would enable the EDPB to learn more about emerging issues and develop relevant guidelines that better align with the practical realities faced by businesses, ultimately promoting more robust and effective data protection compliance. • The need to identify the right legal basis at EU level for the processing of health data for the conclusion and performance of insurance contracts. In order to ensure legal certainty and address barriers to cross-border data transfers, it should be clarified that the processing of health data necessary for this purpose is covered by one of the derogations in the GDPR, such as the one in Art. 9 (2) (f). Each topic is further elaborated in the sections below.

…the derogations in the GDPR, such as the one in Art. 9 (2) (f). Each topic is further elaborated in the sections below. • Insurance Europe welcomes the adoption of the new EU-US Data Privacy Framework and calls on the EC to continue its work to develop new adequacy decisions that allow for the lawful transfer of data outside of the EU while respecting the privacy of EU citizens. Adequacy decisions are the most well-fitting instrument for insurers to transfer data internationally as they provide the Key messages on the EC evaluation of the GDPR November 2023 International data transfers 1 Ref. Ares(2024)939323 - 07/02/2024 2 most appropriate safeguards for both data controllers and data subjects.

Ares(2024)939323 - 07/02/2024 2 most appropriate safeguards for both data controllers and data subjects. However, the current list of countries that are covered by an adequacy decision is still quite limited and falls short of covering data transfers in an environment in which the global exchange of data is on the rise daily. The EC should take note of this gap and speed up the processes for adopting adequacy decisions for third countries and territories with an adequate level of protection. • With the spectre of a possible “Schrems III” case around the corner, the insurance industry calls for continued legal certainty so that EU companies can continue to carry out their business activities. EU companies are still facing severe challenges assessing the legal requirements of third countries.

…activities. EU companies are still facing severe challenges assessing the legal requirements of third countries. With the use of standard contractual clauses (SCCs) and binding corporate rules now dependent on companies’ ability to ensure that privacy standards in the receiving jurisdiction are adequate, companies must now rely on their own resources to conduct burdensome assessments. Rather than investing in a multitude of global law firms providing expertise in each jurisdiction, it should be for the Commission to determine whether the local laws and customs of a third country represent an obstacle to the transfer of personal data to that country. • In its Recommendations 1/2020, the EDPB calls for additional safeguards when using third-country transfer instruments, eg, SCCs.

…1/2020, the EDPB calls for additional safeguards when using third-country transfer instruments, eg, SCCs. In practice, it is often not possible to take the protective measures required by the data protection authorities. Unfortunately, the authorities do not apply the risk-based approach inherent in the GDPR in this respect. This often makes cloud solutions impossible to use even in the case of very low risk, such as a business video conference with the use of exclusively professional contact data. Art. 24 and 32 GDPR provide for a risk-based approach to the determination of technical and organisational measures for the protection of data subjects. Although this risk-based approach is not explicitly stated in the regulations on transfers to third countries in the GDPR (Art. 44 ff), it should also apply here without restriction.

…regulations on transfers to third countries in the GDPR (Art. 44 ff), it should also apply here without restriction. • The GDPR already provides alternative tools for international transfers. The derogations provided for in Art. 49 GDPR for cases in which the level of data protection in third countries is not adequate could be helpful but they should not be interpreted too narrowly. For example, Art. 49 (1) (a) GDPR permits data transfers on the basis of the data subject’s explicit consent after being informed of the possible risks of such transfers. The exceptional nature of the provision is already accounted for through the increased informational requirements compared with consent pursuant to Art. 6 and 9 GDPR. In contrast, there are no restrictions on the possibility of consent either in the wording or in the recitals.

…9 GDPR. In contrast, there are no restrictions on the possibility of consent either in the wording or in the recitals. The EDPB should therefore be notified that the requirement to only allow consent in exceptional cases imposes a new restriction that was not originally envisaged by co- legislators at the time the GDPR was finalised. • The current very low number of code of conducts can be linked to the high requirements imposed by the EDPB. In its Guidelines 1/2019, the EDPB stated that the establishment of a private monitoring body is an indispensable condition for approving any code of conduct. However, according to Article 41 GDPR, which is designed as a “may” clause, the establishment of a private monitoring body is optional.

…to Article 41 GDPR, which is designed as a “may” clause, the establishment of a private monitoring body is optional. Due to the fact that the GDPR must apply to all industries, codes of conduct, which include industry-related specifications, create legal certainty for users and facilitate the work of the supervisory authorities. Article 40(1) GDPR therefore rightly specifies the legislators’ objective to encourage the drawing up of codes of conduct. There are concerns, however, that the high requirements of the EDPB might impede the achievement of this objective. Therefore, consideration should be given to initiatives aimed at ensuring that monitoring bodies are considered optional. • The Recommendations 1/2022 of the EDPB on Controller Binding Corporate Rules (BCRs) and the very long duration of the approval process in practice so far make BCRs within the meaning of Art.

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Position Paper Insurance Europe views on the EC report on the review of the GDPR Our reference: COB-DAT-20-030 Date: 28 April 2020 Referring to: European Commission consultation on EC report on the review of the GDPR Contact person: Ana-María López-Chicheri Llorente, Policy Advisor, Conduct of Business E-mail: [email protected] Pages: 19 Transparency Register ID no.: 33213703459-54 Introduction Insurance Europe welcomes the various opportunities offered by the European Commission (EC) to provide input to its report on the evaluation and review of the General Data Protection Regulation (GDPR). Insurance Europe has already responded to the EC stakeholder questionnaires1 and is now pleased to comment on the EC roadmap consultation on the report of the GDPR.

EC stakeholder questionnaires1 and is now pleased to comment on the EC roadmap consultation on the report of the GDPR. Insurance Europe invites the EC to consider the following aspects: Comments on the form and content of the GDPR review report: The EC report should not open the text of the GDPR for amendments in 2020: Although it contains challenges for business, revising the GDPR after only two years since the Regulation became applicable to introduce amendments would be premature and counterproductive. Like many other sectors, the insurance industry has invested significant resources to understand the Regulation and its implications for our sector and to ensure a proper implementation of the new regime. Opening the GDPR for review at such an early stage would undermine the industry’s efforts and investments to comply with the Regulation.

…for review at such an early stage would undermine the industry’s efforts and investments to comply with the Regulation. Instead, Insurance Europe recommends that the EC report focuses on taking stock of the experiences gained since the application of the Regulation in May 2018, and if areas where the GDPR has failed to meet its objectives are identified, considers the development of further or different guidance, together with the European Data Protection Board (EDPB), where relevant. The EC report should take stock beyond the mandate established in Article 97 GDPR: Article 97 GDPR mandates the EC to issue a report identifying any issues on the application of the GDPR and instructs the EC to focus the assessment on the international transfer of personal data to third countries and on the adequacy and consistency mechanism (Chapters V and VII respectively).

…of personal data to third countries and on the adequacy and consistency mechanism (Chapters V and VII respectively). Insurance Europe recommends that the EC takes stock beyond Chapters V and VII of the Regulation and includes the following aspects into the report: The EC, as the guardian of European Law, should include a dedicated section in the report on the role of the EDPB and the impact of its GDPR guidelines on industries. In particular, this section should address the areas where the interpretation of the EDPB, has gone 1 Insurance Europe is a member of the EC multi-stakeholder group on GDPR and submitted input to the stock-taking questionnaires on the functioning of the GDPR in April 2019 and February 2020. Ref.

…submitted input to the stock-taking questionnaires on the functioning of the GDPR in April 2019 and February 2020. Ref. Ares(2020)2274881 - 28/04/2020 2 beyond the political agreement in the text of the GDPR by, for example, creating additional requirements or narrowing the interpretation of a GDPR provision2. The EC should use the report on the application of the GDPR to reinforce its role as the guardian of the Regulation and to stress that the EDPB’s mandate is subjected to the political agreement in the text of the GDPR. In the interest of European consistency in the application of the GDPR, the EC report should consider assessing whether certain national GDPR guidelines have created fragmentation in the application of the Regulation.

…assessing whether certain national GDPR guidelines have created fragmentation in the application of the Regulation. For example, the guidance on cookies and tracers issued by the Spanish data protection authority (DPA) does not follow the same criteria that is used by the French and UK DPAs regarding the mechanisms to obtain consent from the data subject. These discrepancies at national level have also arisen in guidelines concerning data protection impact assessments or legitimate interest, where DPAs have established differing criteria. It is paramount that the EC pursues a unified approach to the interpretation and application of the GDPR throughout Europe.

…paramount that the EC pursues a unified approach to the interpretation and application of the GDPR throughout Europe. Furthermore, as explained further below, the EC report should assess: - The impact of the GDPR on innovation and address any obstacles the regulation may have unintentionally created to the development of innovative and emerging technologies such as blockchain, artificial intelligence, big data or the internet of things. These technologies offer great opportunities for insurers and consumers, but innovation developments could be undermined in the sector if innovation attempts challenge GDPR provisions and/or EDPB guidelines. - The interplay between the GDPR and the ePrivacy proposal and propose to align the legal bases provided in both Regulations to process data.

…the GDPR and the ePrivacy proposal and propose to align the legal bases provided in both Regulations to process data. - The tools for international data transfer, and suggest ways to address any existing insufficiencies to ensure that European companies can rely on the tools provided in the GDPR. - Whether DPAs are provided with sufficient resources according to their needs to ensure a European level playing field in the enforcement of the GDPR. Comments on unintended barriers on the development of technology in insurance: Blockchain technology and GDPR: The underlying principles of blockchain technology raise certain questions about compatibility with the GDPR. For example, how to reconcile the GDPR’s rights to erasure and to rectification with the fact that blockchain technology is designed to be an immutable and permanent record of all transactions is unclear.

…the fact that blockchain technology is designed to be an immutable and permanent record of all transactions is unclear. This lack of clarity may hinder the development of solutions based on blockchain technology by insurers. The EC should take note that the principle of “technological neutrality” should be preserved in any legislation and guidance. Insurance Europe recommends that the EC works closely with the EDPB, to address any necessary clarifications on the interplay between the GDPR and blockchain, and provide the necessary legal certainty to develop solutions based on blockchain technology. Article 29 Working Party Guideline on automated individual decision-making and profiling: The GDPR establishes a general prohibition on the use of solely automated decision- making processes, including profiling, that have legal or similar effects on individuals (Article 22.1 GDPR).

…decision- making processes, including profiling, that have legal or similar effects on individuals (Article 22.1 GDPR). However, the GDPR provides a number of exemptions to this rule, including the “necessity to perform or enter into a contract” (Article 22.2 (a) GDPR). Therefore, solely automated decisions, as described, are allowed when they are necessary to perform or enter into a contract. This could be the case, as explained by the Guidelines, where the amount of data being processed cannot be treated by humans in a timely manner. The barriers for insurers to use solely automated processes comes from the interpretation that the Guidelines give to the threshold that needs to be fulfilled to prove the “necessity” of the solely 2 See the annex to this document: Insurance Europe’s table on its key contributions to the EDPB’s draft guideline consultations.

…annex to this document: Insurance Europe’s table on its key contributions to the EDPB’s draft guideline consultations. 3 automated process to perform/enter into the contract. In this regard, the Guidelines state on page 23 that “the controller must be able to show that this type of processing is necessary, […]. If other effective and less intrusive means to achieve the same goal exist, then it would not be “necessary”. This narrow interpretation imposes an extremely high burden on insurers, who are forced to prove case by case the “necessity” of carrying out the solely automated processes. This situation may create difficulties to offer innovative products based on solely automated techniques, depriving insurers of business opportunities and prejudicing consumers.

…products based on solely automated techniques, depriving insurers of business opportunities and prejudicing consumers. For example, an insurance company may offer online motor insurance through a mobile phone app, where the consumer can obtain coverage simply by sending a picture of the car and providing the requested data via an app. The premium is automatically calculated, and the contract is entered into when the payment is effective. In this case, the narrow interpretation of “necessity” could prevent insurers from offering a “real time” service because it might not be possible to prove in a timely manner, that the calculation of the premium based on solely automated processing is necessary for the performance of the contract. This situation could be extended to the use of solely automated techniques in claims handling processes or in the offer of online travel insurance.

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General comments: Insurance Europe supports the EC’s efforts to update the existing rules in order to adapt value-added tax (VAT) rules to reflect developments in the digital economy. Measures to combat tax fraud, tax evasion, and other initiatives to address non-compliance with tax rules are also supported. Any measure designed to reduce VAT fraud, such as digital reporting requirements (DRRs), must, however, be designed in a way that causes minimal business disruption. Hence, any proposal in the field of VAT, should: Be supported by an impact assessment focused on evaluating the effectiveness of the rules. Foresee a realistic timeline for its implementation to reduce unnecessary administrative burdens and compliance costs. Respect the general principle of not reducing the competitiveness of the European industry with respect to international competitors.

…principle of not reducing the competitiveness of the European industry with respect to international competitors. Moreover, Insurance Europe suggests that the text of the ViDA Directive explicitly confirms the exclusion from the new reporting requirements of transactions of goods and services that are: Exempted from VAT and from invoicing requirements. Exempted from VAT, but are subject to invoicing rules that require: A reference to the appropriate (EU or national) legislation exempting the transaction from invoicing requirements. Any other reference required to prove the exemption from invoicing requirements. In general, while Insurance Europe appreciates the need for harmonising rules on the issuance of invoices and reporting, the EC’s current proposals are too far-reaching and the proposed time frame is not realistic.

…invoices and reporting, the EC’s current proposals are too far-reaching and the proposed time frame is not realistic. E-invoices: (Article 1 repealing Article 232 of the VAT Directive) For Insurance Europe, the date foreseen in the ViDA proposal of 1 January 2024 is too early to introduce digital invoicing in the VAT Directive. Insurance Europe suggests postponing the deletion of Article 232 of the existent VAT Directive, which foresees the necessity of the recipient’s approval before the issuance of an electronic invoice, for at least one full year (eg until 1 January 2025). The postponement would give member states and businesses enough time to adapt to the transposition of the Directive into national law.

…would give member states and businesses enough time to adapt to the transposition of the Directive into national law. (Article 4 amending Article 222 of the VAT Directive) The two-day timeline, foreseen by the amendments to Article 222 of the existing VAT Directive included in the proposed ViDA Directive, is too short. This is because two days are not enough for: The issuance of electronic invoices after that the chargeable event took place, especially in large corporations. Checking possible mismatches and, if needed, to notify tax authorities. Moreover, several other possible issues and/or questions could arise from the introduction of a two-day deadline: The new deadline would require the introduction of new EU-wide rules regulating the timing for the supply of services, in order to ensure consistency across member states.

EU-wide rules regulating the timing for the supply of services, in order to ensure consistency across member states. For instance, in the case of continuous services, how would the timing of the supply of those services be determined? The EC should specify if there would be any penalty for not meeting the two-day requirement. Response to EC consultation on the adopted text of the proposal for a VAT in the digital age (ViDA) Directive Ref. Ares(2023)2408889 - 03/04/2023 Therefore, Insurance Europe suggests that the text of ViDA Directive is modified to maintain the deadline of 45 days from the moment when the chargeable event occurred, as provided for in the existing VAT Directive.

…deadline of 45 days from the moment when the chargeable event occurred, as provided for in the existing VAT Directive. Summary invoices (Article 4 deleting Article 223 of the VAT Directive): The elimination of the possibility to issue summary invoices, stemming from the deletion of Article 223 foreseen in the proposal for a ViDA Directive, is opposed. In fact, summary invoices are commonly used, and the proposed deletion would cause major business disruption and might be practically impossible to adhere to. Therefore, Insurance Europe asks for the maintenance of the existing Article 223, allowing the use of summary invoices. New data elements requirements (Article 4 amending Article 226 of the VAT Directive) All national invoicing regulations already have their fair share of mandatory data points required on invoices for VAT compliance purposes.

…regulations already have their fair share of mandatory data points required on invoices for VAT compliance purposes. Therefore, Insurance Europe invites the EC to clarify the following aspects: The rationale behind adding new data requirements to the content of invoices, such as the IBAN of the supplier, the agreed dates, and the amounts of payments received. The rationale behind not considering the readily available data to be fit for monitoring or transparency. Digital Reporting Requirement (Articles 262 to 271 of the VAT Directive) The text of the ViDA Directive should explicitly confirm that VAT-exempt transactions, which are not subject to an invoicing requirement, are not in the scope of the new DRRs. Under Article 263, the time limit for the DRR is set to two days as of January 2028, if the ViDA package is adopted. The timeframe is considered too short and should be extended.

…days as of January 2028, if the ViDA package is adopted. The timeframe is considered too short and should be extended. The part of the text of the ViDA Directive concerning DRRs, which is proposed to be implemented as of 1 January 2028, should be placed into a separate legislative proposal. In that case, it might be subject to further discussions and impact assessments without delaying the other parts of the ViDA Directive. Insurance Europe suggests maintaining the existing Article 268, for the following reasons: The new version of Article 268, foreseen in the ViDA Directive, would place an obligation on member states to require data from the taxable persons that, in their territory, perform intra- Community acquisitions of goods or services (or transactions treated as such under Article 21 or 22).

…perform intra- Community acquisitions of goods or services (or transactions treated as such under Article 21 or 22). In the existing VAT Directive, the collection of this data was made an optional choice of member states, which could be requested through recapitulative statements. After the introduction of the new version of Article 268, the acquirer would also have to fulfil digital reporting obligations within the unrealistic deadline of two days. Products and services exempted from VAT: Insurance Europe suggests that: The ViDA Directive should explicitly confirm that those products and services that are exempted from the scope of VAT under Directive 2006/112/EC are also exempted from the scope of the new reporting requirements.

…from the scope of VAT under Directive 2006/112/EC are also exempted from the scope of the new reporting requirements. The ViDA Directive should also include an exemption for outsourced services that are instrumental in carrying out those activities that are already VAT-exempted, like insurance and other financial services. The rationale behind this request is the following: During recent decades, insurance companies have increasingly relied on outsourcing to obtain a wide range of services that are necessary for the execution of their business, leading to increased efficiency. Some categories of outsourced activities might be provided via platforms in the next future.

…to increased efficiency. Some categories of outsourced activities might be provided via platforms in the next future. Services that are often provided by external suppliers (such as underwriting of risk, risk management, policy administration, product development, investment management, telehealth, and claims handling) are to be considered specific and essential to the purpose of carrying out insurance business and, therefore, should benefit from a VAT exemption in all member states, to achieve a true level playing field.

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Insurance Europe aisbl • rue Champ de Mars,23 B-1050 Brussels Tel: +32 2 894 30 00 • E-mail: [email protected] www.insuranceeurope.eu © Reproduction in whole or in part of the content of this document and the communication thereof are made with the consent of Insurance Europe, must be clearly attributed to Insurance Europe and must include the date of the Insurance Europe document.

Europe, must be clearly attributed to Insurance Europe and must include the date of the Insurance Europe document. Response to European Commission call for evidence for evaluating ATAD Our reference: Date: 11 September 2024 Referring to: Anti-tax Avoidance Directive (ATAD) – evaluation Contact person: Fabrizio Franco, Policy advisor, Personal Insurance & Taxation E-mail: [email protected] Pages: 2 Transparency Register ID no.: 33213703459-54 General consideration and fundamental concerns Insurance Europe welcomes the European Commission (EC)’s call for evidence as an opportunity to provide feedback on the upcoming evaluation of the Anti-Tax Avoidance Directive (ATAD).

…evidence as an opportunity to provide feedback on the upcoming evaluation of the Anti-Tax Avoidance Directive (ATAD). The European (re)insurance industry is concerned about the inefficiencies and high compliance costs (eg, personnel, IT, and data systems) arising from the overlap of ATAD, with the Global Minimum Corporate Taxation Directive (GloBE rules), and the Sixth Directive on Administrative Cooperation (DAC 6). These multiple regimes create a complex and burdensome environment for businesses, especially Multinational Enterprises (MNEs). For these reasons, European (re)insurers recommend the following approaches: Repealing ATAD The introduction of the GloBE rules has diminished the original justification behind ATAD. On top of that, the compliance costs associated with keeping both measures far exceed any potential benefits. Given this, Insurance Europe recommends repealing ATAD.

…with keeping both measures far exceed any potential benefits. Given this, Insurance Europe recommends repealing ATAD. Repealing some ATAD provisions and aligning others to the GloBE rules If a complete repeal of the ATAD is not feasible, Insurance Europe proposes a partial repeal and adjustment: MNE groups subject to the Global Minimum Corporate Tax should be exempt from the Controlled Foreign Company (CFC) rules. Consequently, CFC rules would only apply to MNE groups outside of the scope of the Minimum Corporate Taxation. To simplify and align CFC rules with GloBE for those companies, the industry suggests: Using financial accounting as a starting point for the CFC income computation, as established by GloBE rules. Differently from GloBE rules, income inclusion would be limited to foreign passive income.

…by GloBE rules. Differently from GloBE rules, income inclusion would be limited to foreign passive income. Such income would be subject to a minimum tax rate of 15% using a simplified version of the GloBE income-inclusion rule. Simplification should entail, for instance, eliminating complex rules like those for Partially Owned Parent Entities (POPE). Additionally, CFC rules (Articles 7 and 8 of ATAD) should be amended as follows: Ref. Ares(2024)6436261 - 11/09/2024 2 Extend the optional exemption under Article 7 paragraph 3 to entities controlled by financial undertakings and primarily performing investment functions for the controlling financial undertakings. Exclude transactions by a financial undertaking with entities controlled by it from the calculation of the one-third threshold for the optional exemption in Article 7 paragraph 3.

…controlled by it from the calculation of the one-third threshold for the optional exemption in Article 7 paragraph 3. The interest limitation rule (Article 4) should be transformed into a thin capitalization rule that primarily targets debt owed to shareholders, rather than overall interest expense. The rules related to hybrid mismatches (Articles 9, 9a, and 9b) should be amended as follows: Exclude "structured arrangements" (as defined in Article 2(11)) from the scope of the anti-hybrid rules, as the complexity and ambiguity of these rules create significant compliance burdens. Limit anti-hybrid rules to entities within the same group, connected by a controlling interest. Repeal Article 9(3), addressing imported mismatches.

…within the same group, connected by a controlling interest. Repeal Article 9(3), addressing imported mismatches. The provision imposes excessive compliance costs by requiring to verify the tax treatment of, not only the other party involved in the transaction, but also other parties further down in the transaction chain to ensure that no hybrid mismatches are involved. If not entirely repealed, it should be limited to those cases in which a controlling interest exists. Repealing DAC 6 Similar considerations apply to DAC 6. Given the global minimum corporate tax, abusive cross-border arrangements are less likely. Additionally, the ambiguous language of DAC 6 creates legal uncertainty and administrative burdens. Its hallmarks are poorly suited to combat tax avoidance structures.

…legal uncertainty and administrative burdens. Its hallmarks are poorly suited to combat tax avoidance structures. Conclusions In summary, Insurance Europe urges the European Commission to simplify the tax landscape by reducing overlaps and eliminating unnecessary compliance burdens. Aligning ATAD and DAC 6 with GloBE rules would create a more efficient and competitive business environment for European companies. The EU should avoid duplications to prevent a competitive disadvantage compared to other major economic regions. Insurance Europe is the European insurance and reinsurance federation. Through its 37 member bodies — the national insurance associations — it represents all types and sizes of insurance and reinsurance undertakings. Insurance Europe, which is based in Brussels, represents undertakings that account for around 95% of total European premium income.

…which is based in Brussels, represents undertakings that account for around 95% of total European premium income. Insurance makes a major contribution to Europe’s economic growth and development. European insurers pay out over €1 000bn annually — or €2.8bn a day — in claims, directly employ more than 920 000 people and invest over €10.6trn in the economy.

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