Response to the OECD Consultation on the Secretariat Proposal for a “Unified Approach” under Pillar One

Financial Market Infrastructures (FMIs) such as Trading Venues, Central Counter Parties (CCPs), Central Securities Depositories (CSDs) and Organised Market Places (OMPs), have a very specific role within the financial services industry. They ensure that the trading, clearing and settlement of financial instruments is done in an efficient way and in a risk-controlled environment.

It should be considered that including FMIs in the framework for digital taxation could have unintended consequences, potentially negatively affecting companies’ ability to raise financing and hedge their risk. FESE therefore stands ready to contribute to the discussions going forward on the introduction of an explicit carve-out of FMIs and financial instruments, including spot commodity markets.