GERMANY/ NETHERLANDS - ABP, the €193bn Dutch pension fund for civil servants, and VBL, the €13bn German public sector supplementary insurer, are working together to create a new scheme for a Dutch-German border hospital.

The university clinics of Maastricht (in the Netherlands), workers of which are insured by ABP, and Aachen (in Germany), which is in turn insured by VBL, have launched the initiative to set up a cardiovascular centre right on the German/Dutch border.

Wim Moes, director of product research and development at APG, the asset manager and pension provider of ABP, told IPE the clinic was not yet under construction, though he and VBL's president, Wolf Thiel, have been trying to find a way of organising occupation pensions provision for Dutch and German employees of the new centre.

Moes and Thiel are grappling with the different social security, tax and pension systems in the two countries, and the differing statuses of the funded ABP scheme and VBL's pay-as-you-go systems.

Thiel revealed yesterday one of the plans was to found a new legal entity that could be a member of both ABP and VBL, as the principle of ‘lex loci laboris' - the law of the place of work - does not apply.

Thiel and Moes envisage a so-called ‘zip principle', with a fair distribution of newly-hired employees to either VBL or ABP.

Belgian pension expert Paul Roels commented such a new legal entity using a ‘zip principle' might be overruled by the IORP directive, because legislation forces one to apply the rules of where one works.

Yet ABP and VBL believe there might be some leeway in the labour laws which could facilitate the zip principle.

Thiel concluded: "We are confident that we will find a way."

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