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2019 | OriginalPaper | Buchkapitel

5. United Kingdom’s Seed Enterprise Investment Scheme

verfasst von : Stephen Barkoczy, Tamara Wilkinson

Erschienen in: Incentivising Angels

Verlag: Springer Singapore

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Abstract

As mentioned in Chap. 1, the United Kingdom has developed its own angel tax incentive program, known as the Seed Enterprise Investment Scheme (SEIS). The SEIS was introduced in 2012 and is designed to help small, high-risk companies raise equity capital by offering tax incentives to individuals who subscribe for ordinary shares in them. While Australia’s ESI program discussed in Chap. 4 was loosely modelled on the SEIS, the programs have a number of significant differences. For instance, although both programs target investments in small early stage companies, they contain quite different eligibility criteria. The SEIS, for example, focuses on criteria such as a company’s gross assets and the number of its employees, whereas the ESI program focuses on criteria such as a company’s expenses and assessable income. The SEIS also contains a blacklist of ‘excluded activities’ that an investee company must not carry on, whereas the ESI program does not have such a list. In addition, while the ESI program uses a ‘point-in-time’ test to determine whether a company qualifies as an ESIC, several SEIS requirements are ‘ongoing’, meaning that if they cease to be met during the relevant period, tax benefits that have been granted to investors may be withdrawn. Another key difference between the programs is that the SEIS does not require investee companies to meet any specific ‘innovation requirements’ like the ones that exist under the ESI program. There are also important differences in the nature of the tax incentives provided under the programs. While both the SEIS and the ESI program use a combination of front-end and back-end tax incentives to encourage angel investment, the SEIS provides a broader range of tax incentives than the ESI program. This chapter closely examines the SEIS and compares and contrasts it with the ESI program as well as Australia’s formal venture capital tax incentive programs discussed in Chap. 3. The comparative discussion in this chapter is then used to inform the suggestions we make for reforms to the ESI program in Chap. 6.

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Vorheriges Kapitel Australia’s Early Stage Investor Program

Nächstes Kapitel Suggestions for Reforming Australia’s Early Stage Investor Program

The SEIS was introduced by the Finance Act 2012 (UK), which amended the Income Tax Act 2007 (UK) (‘ITA 2007 (UK)’).

ITA 2007 (UK) ss 257A, 257AA.

ITA 2007 (UK) s 257AAA.

An investor will be a qualifying investor if they meet the requirements set out in Chapter 2 of Part 5A of the ITA 2007 (UK): s 257B.

The general requirements are set out in Chapter 3 of Part 5A of the ITA 2007 (UK): s 257C.

A company will be a qualifying company if it meets the requirements set out in Chapter 4 of Part 5A of the ITA 2007 (UK): s 257D.

Venture Capital Trusts must be approved by HM Revenue & Customs to operate as formal venture capital funds. They invest in (or make loans to) underlying investee companies, which must be unlisted (among other things). Investors in Venture Capital Trusts can receive front-end income tax relief for the purchase of shares in a Venture Capital Trust and back-end CGT relief in relation to gains they make on their investments: HM Revenue & Customs, ‘Tax Relief for Investors Using Venture Capital Schemes’ (Guidance, 3 October 2018) <https://www.gov.uk/guidance/venture-capital-schemes-tax-relief-for-investors>. See also HM Revenue & Customs, ‘Venture Capital Schemes Manual: Venture Capital Trusts: Contents’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm50000>.

The Enterprise Investment Scheme provides a range of tax incentives to individuals who invest in small, high-risk companies. The scheme offers up-front income tax relief, back-end CGT and loss relief, and CGT deferrals where capital gains are reinvested under the scheme: HM Revenue & Customs, ‘Tax Relief for Investors Using Venture Capital Schemes’ (n 7). See also HM Revenue & Customs, ‘Use the Enterprise Investment Scheme (EIS) to Raise Money for Your Company’ (Guidance, 12 October 2018) <https://www.gov.uk/guidance/venture-capital-schemes-apply-for-the-enterprise-investment-scheme>. The Enterprise Investment Scheme also allows for managed ‘EIS investment funds’ to be formed, which make investments on behalf of individuals. In this respect, the scheme possesses some of the features of a formal venture capital program: see further HM Revenue & Customs, ‘Venture Capital Schemes Manual: EIS: Income Tax Relief: Supplementary and General: Approved Investment Fund as Nominee’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm16050>.

The similarities between the two schemes were viewed positivity by some commentators, one of whom noted that companies can raise capital through the SEIS before moving on to raising capital through the Enterprise Investment Scheme or Venture Capital Trust scheme ‘without the need for two separate sets of rules’: Andrew Harper, ‘Finance Act Notes: Section 38 and Schedule 6: Seed Enterprise Investment Scheme’ (2012) 4 British Tax Review 407, 410. This is also beneficial for the tax system, as it avoids the complexity of introducing a wholly independent third scheme: at 410.

For instance, companies under the SEIS must have fewer gross assets and employees than those under the Enterprise Investment Scheme, they are significantly more limited in how much investment they may receive through ‘risk capital schemes’ (e.g., venture capital incentives) and they can only have been trading for two years or less (whereas companies under the Enterprise Investment Scheme have much more lax age requirements): see ITA 2007 (UK) ss 173A, 175A, 186, 186A, 257 DC, 257DL, 257DI, 257DJ, 257HF. The fact that the SEIS targets smaller and newer companies explains why it is called the ‘Seed’ Enterprise Investment Scheme.

HM Revenue & Customs, ‘Enterprise Investment Scheme and Seed Enterprise Investment Scheme April 2017 Statistics on Companies Raising Funds’ (Official Statistics Release, 27 April 2017) <https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/611524/April_2017_Commentary_EIS_SEIS_Official_Statistics_v5.pdf>. The rate of income tax relief available under the SEIS is 50% of the invested amount, compared to 30% under the Enterprise Investment Scheme. However, it should be noted that investors can invest greater amounts under the Enterprise Investment Scheme (up to £2 million in certain circumstances, compared to £100,000 under the SEIS): HM Revenue & Customs, ‘Tax Relief for Investors Using Venture Capital Schemes’ (n 7).

The risk to capital condition applies from 15 March 2018 and corresponding conditions also exist under the Enterprise Investment Scheme and the Venture Capital Trusts scheme: ITA 2007 (UK) ss 157A, 257AAA, 286ZA; HM Revenue & Customs, ‘Venture Capital Schemes Manual: Risk-To-Capital Condition: An Overview of the Risk-To-Capital Condition’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm8530>.

ITA 2007 (UK) s 257AAA. The net investment return takes into account the value of SEIS tax relief received by the investor.

HM Revenue & Customs, ‘Income Tax: Venture Capital Schemes – Risk to Capital Condition’ (Policy Paper, 22 November 2017) <https://www.gov.uk/government/publications/income-tax-venture-capital-schemes-risk-to-capital-condition/income-tax-venture-capital-schemes-risk-to-capital-condition>.

Ibid. It has been noted that ‘companies that are comfortably in line with the stated purpose of the venture capital schemes should meet the risk-to-capital condition’: HM Revenue & Customs, ‘Venture Capital Schemes Manual: Risk-To-Capital Condition: An Overview of the Risk-To-Capital Condition’ (n 12).

ITAA 1997 ss 118-425(1), 118-427(1).

ITA 2007 (UK) s 257AA. Tax relief may also be available where an individual subscribes for and holds shares through a nominee: s 257HE. This exception does not, however, allow investors to obtain income tax relief if they invest in a partnership which in turn invests in shares (because the individual would own a proportion of all the partnership assets rather than having sole ownership of a specific allocation of shares): HM Revenue & Customs, ‘Venture Capital Schemes Manual: SEIS: Income Tax Relief: Supplementary and General: Nominees and Bare Trustees’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm37040>.

ITA 2007 (UK) s 257BA; HM Revenue & Customs, ‘Venture Capital Schemes Manual: SEIS: Income Tax Relief: The Investor: No Employee Investors’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm32020>. The fact that directors who are also investors in a company are not treated as employees for the purposes of the SEIS is a sensible design feature that allows angels to play a role in managing their investee companies without affecting their entitlement to the tax incentives: European Commission, ‘Effectiveness of Tax Incentives for Venture Capital and Business Angels to Foster the Investment of SMEs and Start-ups: Final Report’ (Working Paper No 68, European Commission, June 2017) 77–8.

ITA 2007 (UK) s 257BB. Harper notes that the claimed justification for the substantial interest rule is that the Government is ‘keen to promote external investment in start-ups rather than reward founder capital’, which is subsidised under another Government program known as ‘Entrepreneurs’ Relief’: Andrew Harper, ‘Finance Act Notes: Section 56: SEIS: Income Tax Relief; Section 57: SEIS: Re-Investment Relief’ (2013) 4 British Tax Review 443, 446.

ITA 2007 (UK) s 257BF.

ITA 2007 (UK) s 257 BC.

ITA 2007 (UK) s 257BD.

ITA 2007 (UK) s 257BE.

ITA 2007 (UK) s 257CA. From the time when the shares are issued until the third anniversary of their issue, they must not carry any present or future preferential rights to dividends, to a company’s assets on its winding up, or to be redeemed.

A qualifying business activity can include a ‘new qualifying trade’ (see below), as well as R&D that the company is undertaking from which it is intended that a new qualifying trade will be derived: ITA 2007 (UK) s 257HG.

A subsidiary is a qualifying 90% subsidiary of another company (‘the relevant company’) for the purposes of the SEIS where: the relevant company has at least 90% of the subsidiary’s issued share capital and 90% of the voting power in the subsidiary; in the event of winding up or any other circumstances, the relevant company would be beneficially entitled to receive at least 90% of the subsidiary’s assets which would then be available for distribution to equity holders of the subsidiary; the relevant company is beneficially entitled to receive at least 90% of any profits of the subsidiary which are available for distribution to equity holders of the subsidiary; no person other than the relevant company has control of the subsidiary; and no arrangements exist by virtue of which any of the above conditions would cease to be met: ITA 2007 (UK) ss 190, 257HJ.

ITA 2007 (UK) ss 257 AC, 257CB, 257CC.

ITA 2007 (UK) s 257CD.

ITA 2007 (UK) s 257 CE.

ITA 2007 (UK) s 257CF. The meaning of ‘disqualifying arrangements’ is set out in the relevant section. HM Revenue & Customs has noted that the purpose of this requirement is ‘to prevent the schemes being used primarily for the purpose of delivering a tax mitigation product to investors with little or no other commercial purpose; or of delivering the benefits of tax-advantaged finance to another entity or project which would not itself qualify for support under the schemes or whose owners do not want to relinquish equity’: HM Revenue & Customs, ‘Venture Capital Schemes Manual: SEIS: Income Tax Relief: General Requirements: No Disqualifying Arrangements Requirement’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm33080>.

The ESI program nevertheless operates subject to the general anti-avoidance rules contained in Part IVA of the Income Tax Assessment Act 1936 (Cth).

The SEIS features an ‘advance assurance’ facility, whereby companies can receive guidance on whether they are likely to meet the SEIS requirements: HM Revenue & Customs, Apply for Advance Assurance on a Venture Capital Scheme (31 August 2018) Gov.uk <https://www.gov.uk/guidance/venture-capital-schemes-apply-for-advance-assurance>. Between the commencement of the SEIS in 2012 and March 2017, a reported 13,645 ‘Advance Assurance Applications’ were received, of which approximately 85% were approved: HM Revenue & Customs, ‘Enterprise Investment Scheme and Seed Enterprise Investment Scheme’ (Statistics, April 2017) <https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/611525/Combined_tables_to_publish.pdf>.

As noted in Chapter 4, the ESI program does not have any ongoing requirements. The Australian Government has noted that ongoing activity checks would impose an unnecessary regulatory burden on ESICs and increase risk and uncertainty for investors: Explanatory Memorandum, Tax Laws Amendment (Tax Incentives for Innovation) Bill 2016 (Cth) 1.31–1.32.

ITA 2007 (UK) s 257DE. The financial health requirement is that the issuing company must not be ‘in difficulty’. A company is ‘in difficulty’ if it is reasonable to assume that it would be regarded as a firm in difficulty for the purposes of the Community Guidelines on State Aid for Rescuing and Restructuring Firms in Difficulty [2004] OJ C 244/2 (no longer in force).

ITA 2007 (UK) s 257DF. An unquoted company means a company none of whose shares, stocks, debentures or other securities are marketed to the general public. A company’s securities are taken to be marketed to the general public if they are listed on a recognised stock exchange.

ITA 2007 (UK) s 257DI.

ITA 2007 (UK) s 257DJ.

ITA 2007 (UK) s 257DK.

ITA 2007 (UK) s 257DL. Harper notes that unless a company has been ‘preparing to trade’ for a long period of time, this limit will effectively be a lifetime limit ‘because after three years have passed they will no longer have a “new qualifying trade” for the purposes of the scheme’: Harper, ‘Finance Act Notes: Section 38 and Schedule 6: Seed Enterprise Investment Scheme’ (n 9) 409.

ITAA 1997 ss 118-425(6), 118-427(7), 118-440.

ITA 2007 (UK) s 257 AC.

ITA 2007 (UK) s 257DA.

Relevant preparation work refers to the activity of preparing to carry on a new qualifying trade which is intended (and has begun) to be carried on by the company or its qualifying 90% subsidiary. Preparations must be the subject of the company’s relevant qualifying business activity. Relevant R&D refers to R&D which, immediately after the date the relevant shares are issued, the company or its qualifying 90% subsidiary carries on (or will begin to carry on), from which it is intended that a new qualifying trade will be derived, or will benefit. The R&D must be the subject of the company’s relevant qualifying business activity: ITA 2007 (UK) ss 257 DC, 257HG.

ITA 2007 (UK) ss 257 DC, 257HF.

ITA 2007 (UK) s 257DD.

A subsidiary is a qualifying subsidiary of another company (‘the relevant company’) for the purposes of the SEIS where: the subsidiary is a 51% subsidiary of the relevant company; no person other than the relevant company, or another of its subsidiaries, has control of the subsidiary; and no arrangements exist by virtue of which either of the above conditions would cease to be met: ITA 2007 (UK) ss 191, 257HJ.

ITA 2007 (UK) s 257DG. It has been noted that the independence requirement is ‘intended to prevent established trading companies from temporarily spinning off subsidiaries to allow investors access to the generous tax reliefs on offer’: United Kingdom, Parliamentary Debates, House of Commons, 11 June 2013, sitting 13, col 418 (David Gauke).

ITA 2007 (UK) s 257DH.

ITA 2007 (UK) s 257DM.

ITA 2007 (UK) s 257DN. A ‘property managing subsidiary’ means a subsidiary of the company whose business consists wholly or mainly in the holding or managing of land or any property deriving its value from land.

ITA 2007 (UK) ss 257 DC, 257HF.

ITA 2007 (UK) ss 189, 257HF.

Other excluded activities include: dealing in commodities, futures, shares or other financial instruments; dealing in goods otherwise than in the course of an ordinary trade of wholesale or retail distribution; providing legal or accountancy services; farming or market gardening; forestry activities or timber production; shipbuilding; producing coal or steel; operating or managing hotels; operating or managing nursing homes; generating or exporting electricity; generating heat or any other form of energy; and producing gas or fuel: see further ITA 2007 (UK) ss 192-199.

ITA 2007 (UK) s 257 EB.

ITA 2007 (UK) s 257ED.

ITA 2007 (UK) s 257EC.

ITA 2007 (UK) s 257ED; HM Revenue & Customs, ‘Venture Capital Schemes: SEIS: Income Tax Relief: Company and Investor Procedures: Company Procedures: Overview (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm35080>.

ITA 2007 (UK) s 257AB.

ITA 2007 (UK) s 257FA, FB.

ITA 2007 (UK) ss 257BA, 257FR.

ITA 2007 (UK) ss 257BB, 257FR.

ITA 2007 (UK) ss 257CA, 257FC, 257FD.

ITA 2007 (UK) ss 257DA-257DN, 257FR.

ITA 2007 (UK) ss 257CC, 257FR.

ITA 2007 (UK) ss 257FE-257FO; HM Revenue & Customs, ‘Venture Capital Schemes Manual: SEIS: Income Tax Relief: Withdrawal or Reduction of SEIS Relief: Overview’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm36010>. See ITA 2007 (UK) s 257FE as to the definition of value.

ITA 2007 (UK) s 257AB.

Taxation of Chargeable Gains Act 1992 (UK) s 150E.

Taxation of Chargeable Gains Act 1992 (UK) s 150E(4), (5); HM Revenue & Customs, ‘Venture Capital Schemes Manual: Seed Enterprise Investment Scheme (SEIS): SEIS Disposal Relief: Income Tax Relief Restricted’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm40040>.

HM Revenue & Customs, ‘Venture Capital Schemes Manual: Seed Enterprise Investment Scheme (SEIS): SEIS Disposal Relief: CGT Exemption Restricted’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm40030>.

HM Revenue & Customs, ‘Venture Capital Schemes Manual: Seed Enterprise Investment Scheme (SEIS): SEIS Disposal Relief: CGT Exemption’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm40020>. However, this restriction does not apply if the investor’s income tax liability is reduced to nil because of the SEIS income tax relief: HM Revenue & Customs, ‘Venture Capital Schemes Manual: Seed Enterprise Investment Scheme (SEIS): SEIS Disposal Relief: Income Tax Relief Restricted’ (n 68).

Taxation of Chargeable Gains Act 1992 (UK) s 150E.

Reinvestment relief was originally meant to be a temporary measure, but was extended in 2014. It was originally introduced ‘to kick-start the scheme and create a buzz’: United Kingdom, Parliamentary Debates, House of Commons, 11 June 2013, sitting 13, col 418 (David Gauke). The relief was extended as a response to a perceived slow take up of the SEIS. One commentator has, however, questioned whether this was an appropriate response, considering that the scheme was ‘already one of the most generous investment incentives of its kind’: Harper, ‘Finance Act Notes: Section 56: SEIS: Income Tax Relief; Section 57: SEIS: Re-Investment Relief’ (n 19) 445.

HM Revenue & Customs, ‘HS393 Seed Enterprise Investment Scheme – Income Tax and Capital Gains Tax reliefs (2018)’ (Guidance, 9 April 2018) <https://www.gov.uk/government/publications/seed-enterprise-investment-scheme-income-tax-and-capital-gains-tax-reliefs-hs393-self-assessment-helpsheet/hs393-seed-enterprise-investment-scheme-income-tax-and-capital-gains-tax-reliefs-2018#which-seis-shares-qualify-for-reinvestment-relief>.

Taxation of Chargeable Gains Act 1992 (UK) s 150G, Sch 5BB. See further HM Revenue & Customs, ‘Venture Capital Schemes Manual: Seed Enterprise Investment Scheme (SEIS): Re-Investment Relief: Introduction’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm45010>.

HM Revenue & Customs, ‘HS393 Seed Enterprise Investment Scheme – Income Tax and Capital Gains Tax reliefs (2018)’ (n 73).

HM Revenue & Customs, ‘Venture Capital Schemes Manual: Seed Enterprise Investment Scheme (SEIS): Re-Investment Relief: Relief Reduced or Withdrawn’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm45090>.

HM Revenue & Customs, ‘Venture Capital Schemes Manual: Seed Enterprise Investment Scheme (SEIS): Re-investment Relief: Relief Restricted’ (16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm45040>.

These countries comprised the European Union nations as well as selected OECD countries: European Commission (n 18) 4, 202.

The European Commission has noted that the provision of loss relief has been linked with encouraging greater risk-taking among investors: ibid 11.

Ibid 204.

Ibid 202–3.

Ibid.

Community Guidelines on State Aid for Rescuing and Restructuring Firms in Difficulty [2004] OJ C 244/2

European Commission, ‘Effectiveness of Tax Incentives for Venture Capital and Business Angels to Foster the Investment of SMEs and Start-ups: Final Report’ (Working Paper No 68, European Commission, June 2017)

Explanatory Memorandum, Tax Laws Amendment (Tax Incentives for Innovation) Bill 2016 (Cth)

Finance Act 2012 (UK)

Harper, Andrew, ‘Finance Act Notes: Section 38 and Schedule 6: Seed Enterprise Investment Scheme’ (2012) 4 British Tax Review 407

Harper, Andrew, ‘Finance Act Notes: Section 56: SEIS: Income Tax Relief; Section 57: SEIS: Re-Investment Relief’ (2013) 4 British Tax Review 443

HM Revenue & Customs, ‘Apply for Advance Assurance on a Venture Capital Scheme’ (Guidance, 31 August 2018) <https://www.gov.uk/guidance/venture-capital-schemes-apply-for-advance-assurance>

HM Revenue & Customs, ‘Enterprise Investment Scheme and Seed Enterprise Investment Scheme’ (Statistics, April 2017) <https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/611525/Combined_tables_to_publish.pdf>

HM Revenue & Customs, ‘Tax Relief for Investors Using Venture Capital Schemes’ (Guidance, 3 October 2018) <https://www.gov.uk/guidance/venture-capital-schemes-tax-relief-for-investors>

HM Revenue & Customs, ‘Use the Enterprise Investment Scheme (EIS) to Raise Money for Your Company’ (Guidance, 12 October 2018) <https://www.gov.uk/guidance/venture-capital-schemes-apply-for-the-enterprise-investment-scheme>

HM Revenue & Customs, ‘Venture Capital Schemes Manual: EIS: Income Tax Relief: Supplementary and General: Approved Investment Fund as Nominee’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm16050>

HM Revenue & Customs, ‘Venture Capital Schemes Manual: Risk-To-Capital Condition: An Overview of the Risk-To-Capital Condition’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm8530>

HM Revenue & Customs, ‘Venture Capital Schemes Manual: Seed Enterprise Investment Scheme (SEIS): Re-Investment Relief: Introduction’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm45010>

HM Revenue & Customs, ‘Venture Capital Schemes Manual: Seed Enterprise Investment Scheme (SEIS): SEIS Disposal Relief: Income Tax Relief Restricted’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm40040>

HM Revenue & Customs, ‘Venture Capital Schemes Manual: SEIS: Income Tax Relief: General Requirements: No Disqualifying Arrangements Requirement’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm33080>

HM Revenue & Customs, ‘Venture Capital Schemes Manual: SEIS: Income Tax Relief: Supplementary and General: Nominees and Bare Trustees’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm37040>

HM Revenue & Customs, ‘Venture Capital Schemes Manual: SEIS: Income Tax Relief: The Investor: No Employee Investors’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm32020>

HM Revenue & Customs, ‘Venture Capital Schemes Manual: SEIS: Income Tax Relief: Withdrawal or Reduction of SEIS Relief: Overview’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm36010>

HM Revenue & Customs, ‘Venture Capital Schemes: SEIS: Income Tax Relief: Company and Investor Procedures: Company Procedures: Overview (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm35080>

HM Revenue & Customs, ‘Venture Capital Schemes Manual: Venture Capital Trusts: Contents’ (HMRC Internal Manual, 16 October 2018) <https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/vcm50000>

Income Tax Act 2007 (UK)

Income Tax Assessment Act 1936 (Cth)

Income Tax Assessment Act 1997 (Cth)

Taxation of Chargeable Gains Act 1992 (UK)

United Kingdom, Parliamentary Debates, House of Commons, 11 June 2013, sitting 13, col 418 (David Gauke)

Titel: United Kingdom’s Seed Enterprise Investment Scheme
verfasst von: Stephen Barkoczy
Tamara Wilkinson
Verlag: Springer Singapore
Buch: Incentivising Angels
Print ISBN: 978-981-13-6631-4

Electronic ISBN: 978-981-13-6632-1

Copyright-Jahr: 2019
DOI: https://doi.org/10.1007/978-981-13-6632-1_5