In the opinion of Germany’s MTG representatives, the wording of Article 3(7), first subparagraph, second sentence of the Financial Conglomerates Directive is ambiguous. Germany’s position is that, for the purposes of identification, the wording “der dem von der Gruppe gehaltenen aggregierten proportionalen Anteil entspricht” (i.e. “aggregated proportional interest held by the group”) is to be understood as the effective shareholding. In Germany’s opinion, this can be deduced from the fact that the regulation is aimed explicitly at shares of group companies, i.e. it does not encompass shares of external non-group entities.
