I am writing to seek clarification regarding the regulatory and practical implications of switching Pan-European Personal Pension Product (PEPP) providers, particularly in a cross-border context. According to Article 52(1), subparagraph 3 of Regulation (EU) 2019/1238, PEPP savers are entitled to switch providers both domestically and across Member States. While the domestic switch appears straightforward, I would appreciate your guidance on two specific issues that arise in the context of cross-border transfers. Sub-Account Structure and Cross-Border Transfers The PEPP framework allows for the creation of sub-accounts corresponding to different Member States, facilitating tax compliance and portability. However, it is unclear how a cross-border switch should be handled when the original provider has sub-accounts in Member States that the new provider does not support. While the Regulation does not explicitly restrict such transfers, practical questions arise regarding the allocation of assets from sub-accounts that are not mirrored by the new provider. For instance, should these assets be consolidated into the sub-account of the Member State where the saver currently resides, or is there an alternative mechanism foreseen by the Regulation? Illustrative Example: A Slovak citizen residing in the Czech Republic holds a PEPP with Finax, with contributions allocated to both Czech and Slovak sub-accounts. Upon relocating to Cyprus, the saver wishes to switch to LifeGoals, the only PEPP provider currently operating in Cyprus. In such a case, how should the assets from the Czech and Slovak sub-accounts be treated during the transfer to the Cypriot provider? Taxation of Cross-Border Transfers Secondly, I would like to inquire whether a Member State may impose a tax on the transfer of a PEPP in a cross-border context. Given that the Regulation explicitly permits such transfers, and considering the overarching principles of the internal market-particularly the free movement of capital and the freedom to provide financial services-it would seem that imposing a tax on such transfers could undermine the objectives of the PEPP framework. While I understand that taxation remains within the competence of Member States, I would appreciate your view on whether such a tax would be compatible with the spirit and intent of the PEPP Regulation and broader EU law. Thank you very much for your time and consideration. I would be most grateful for any clarification or guidance you can provide on these matters.