House of Lords - Economic Affairs

Select Committee on Economic Affairs Second Report

CHAPTER 5: ENCOURAGING ENTERPRISE

231. There are three small clauses in the Finance Bill which make changes to the tax rules for encouraging enterprise. The one we are mainly concerned with in this inquiry is clause 28 which increases the maximum amount of investment in qualifying companies in respect of which an individual may obtain relief in any year under the Enterprise Investment Scheme (EIS). The increase will apply only when it has been brought into effect by Treasury Order. Clause 29 features to a much lesser extent. This clause and associated schedule add shipbuilding and coal and steel production to the activities excluded from the EIS, the Venture Capital Trusts scheme (VCTs) and the Corporate Venturing Scheme (CVS),

232. The EIS was introduced in 1994 and replaced the Business Expansion Scheme by being better focussed. Its purpose is to help small, higher risk, unquoted companies to raise external growth capital. An investor subscribing for new shares will get an income tax reduction of 20% of the cost of his investment for the year. The limit of the relief was raised from £200,000 to £400,000 in 2006; a further increase to £500,000 is now proposed. To retain that income tax relief the investor has to retain the shares for three years and if he does this, he will also obtain relief on any capital gain on the disposal of the shares. Any loss on disposal (restricted for income tax relief already given) can be set against income.

233. The payment of tax on any other capital gain can be deferred where the gain is reinvested in shares of an EIS qualifying company within certain time limits. Income tax relief is denied if the investor is connected with the investee company; a connection can be established either by a financial interest or by being a director or employee, though there is an exception for business angels who become directors on making an investment. Relief is also available for investment through an EIS fund which will invest in a number of EIS qualifying companies.

234. There is a large number of rules that the company must satisfy: be unquoted; not be controlled by another company; rules regarding its subsidiaries; its gross assets cannot exceed £7 million before the investment and £8 million after (reduced from £15/16 million in 2006); have fewer than 50 full-time employees; be carrying on a qualifying trade (most trades qualify except for those which are detailed in a list to which clause 29 adds). There are also rules around the amount of money that can be raised and how and when the money raised can be used. These rules are intended to target the type of company that can qualify, but they are detailed and complex and they led to much comment during the course of our inquiry.

235. Venture Capital Trusts (VCTs) were introduced in 1995 and are for investors who want to invest in the sort of companies which qualify for EIS but wish to invest though a managed fund. The fund has to be structured as a company listed on the London Stock Exchange. Investors can subscribe for, or buy existing shares in a VCT. The listed company must be approved and to achieve this there are detailed rules that it must satisfy including the requirement that 70% of its investments must be shares in companies which qualify under the scheme (essentially the same type of companies as qualify for EIS relief).

236. The investor originally received relief at 20% of the cost of his investment; this went temporarily up to 40% and is now 30%. The maximum investment which attracts relief is £200,000. Any dividends from shares in the VCT are exempt and CGT relief is available on disposing of the shares in the VCT provided they were within the permitted maximum for the year in which they were acquired. Dividend relief and CGT relief are available for new and second-hand shares, but the 30% income tax relief is available only for newly subscribed shares. The VCT itself is exempt from corporation tax on its chargeable gains.

237. The Corporate Venturing Scheme (CVS) provides tax relief for companies which invest directly in the same sort of companies as attract EIS relief. Relief is given at 20% of the amount invested, provided the shares are held throughout a qualification period. Capital gains on the disposal of shares carrying investment relief can be deferred if the gains are reinvested in new shares for which investment relief is obtained. Loss relief against income is available on the disposal of qualifying shares. CVS did not feature in the evidence we heard.

238. At the same time as the announcement of the increase in the limit for a qualifying investment under the EIS, there were a number of other documents published in Budget 2008:

Enterprise: unlocking the UK's talent[81]: this is a very wide ranging document floating various ideas to unlock talent through five 'enablers': culture; knowledge and skills; access to finance; regulatory framework; business innovation. The discussion of the access to finance enabler contains only a brief reference[82] to the EIS and VCTs, outlining the amounts which these schemes have raised.
The Enterprise Investment Scheme: a consultative document[83]: this document is in general looking for ideas as to how the EIS might be simplified, administrative and regulatory burdens reduced and awareness among potential investors raised;
A Study of the Impact of the EIS and VCTs on Company Performance[84]: this is an econometric study published by HMRC but carried out by researchers from the Institute of Employment Studies at the University of Sussex.

The Need for an Increase in the Limit for the Enterprise Investment Scheme

239. One of the causes of complexity in the tax system is the amount of change. Although an increase in the limit for EIS is not in itself a major complication against the background of a Finance Bill of over 400 pages, the recent doubling of the limit and the opening of a debate on support for enterprise generally with the publication of a number of documents on Budget Day, there needs to be a good case for making a further small change this year.

240. We asked our private sector witnesses how they saw the case for this change in the EIS investment limit. None of our witnesses was aware of any direct evidence suggesting that the present limit of £400,000 was restrictive. John Whiting (CIOT) thought that "It seems a bit odd to start a general review of this and then say, 'Here is part of the answer," just as you are starting a review" (Q 72). Richard Baron (IoD) did "not think that the increase to £500,000 was necessary" (Q 197), but he added that he saw the increase in the limit and the consultation document on the detail of the EIS as being pretty well independent of each other.

241. In their written evidence the ICAEW stated that[85] "the changes in this Finance Bill are unlikely to improve the attractiveness of the schemes". The CBI wrote[86] "While the increase is welcome, it is likely to have little effect as very few investors have sufficient resources and income tax liability to invest such a sum in EIS investments and benefit fully from the tax relief". Malcolm Gammie (IFS) thought that "the Government, I assume, reviews the limits which are put in place for these schemes and decides whether or not there will be some incremental value by increasing their limits" (Q 32). The view of Simon Walker (BVCA) was that "every little bit helps" (Q 273).

242. We asked officials about the case for change. Mark Neale (HMT) did not see the increase as "a self-standing measure. It was part of a package of measures in the Budget to ease access to finance for small entrepreneurial businesses. That was against a background when there were concerns that the disruption of financial markets might attenuate access to finance" (Q 372). In the Public Bill Committee[87] the Exchequer Secretary to the Treasury said that the increase was intended to stimulate further investment in small or high risk companies by offering greater incentives to business angels and others, particularly in the light of the current financial situation. She added that the increase had been well received by industry.

243. In their supplementary written evidence, HMT confirmed[88] that "no economic case was published" for "the increase in the enterprise investment scheme investment limit". However, "the Treasury considered a variety of factors such as potential cost and impact, before making this policy change".

244. We are not persuaded that there is a strong case, economic or otherwise, for the increase in the EIS investment limit now. Whilst we accept that the cost of this increase is relatively small, we nevertheless think that the case for change needs to be made and that that case should be published before, or at the same time as, such a change is announced.

245. We recommend that before any further changes are made to the investment limits in any of the venture capital schemes, the economic case for change should be assessed and published, so that it is clear to everyone on what basis the change is being made.

The Effectiveness of the Reliefs

246. There is a large number of different schemes, by no means all in the tax system, which are designed to help small and medium-sized businesses, each having their own rules and restrictions. There are also many regulations which they have to observe. How to strike a balance between all the different considerations goes beyond our remit, but looking at the EIS and the other tax reliefs for venture capital, a relevant question is whether it really is worth all the complexity for businesses, their advisers and HMRC if the rates of tax could be reduced in consequence of their abolition.

247. When asked about this, John Cullinane (CIOT) qualified his answer by stating that the CIOT's members were largely tax practitioners, not economists nor econometricians, and therefore the evidence he received was largely anecdotal. But "Generally we are rather sceptical of the value of these reliefs, while being open to the fact that we would not see all the evidence and we have not undertaken the scientific evidence, if I may put it that way" (Q 73). John Whiting (CIOT) referred to the survey that his firm, PricewaterhouseCoopers, had done and explained "Of potentially eligible companies, we found that two-thirds had heard of the relief, and of those which had used it, precisely half said it had influenced the decision. In other words, half 'would have done it anyway and thank you very much for the relief' and half, 'Yes, it had influenced it'" (Q 73). He concluded that the general message of the survey "was that the message coming back from business … was that they would prefer a lower rate of tax, a simpler system, and less reliefs" (Q 74). In their written evidence the CIOT put it succinctly[89] "A key consideration is surely whether the reliefs change taxpayer behaviour at all".

248. In their written evidence[90] the IoD stated that "it is worth considering whether the extension of existing special reliefs is a sensible way to develop the tax system. There is a case for using any scope for tax reductions to reduce tax rates across the board, rather than to create or extend special reliefs". Frank Haskew (ICAEW) was equally unsure of the benefits of these reliefs "Our experience so far is that, following the changes two years ago to the gross assets test, where effectively the limits were halved, which we understand was the result of problems with state aid, there is very little interest now in EIS schemes, and that the actual volume of investment going into them is quite small" (Q 130). He went on to convey the ICAEW's view "Our suggestion was that there should be a wider-ranging review of the whole enterprise culture. We were not necessarily saying that the scheme should be abolished but we do have a concern that tax is just one part of the wider raft of issues that small businesses in particular need to consider, and that tax is probably potentially quite a small element of that" (Q 131).

249. John Cridland (CBI) echoed the thought of putting these tax schemes in a wider context "If I may comment on the enterprise strategy: there were many elements of the enterprise strategy which the business community will welcome … So we do not have a problem with what is in the enterprise strategy, we have a problem with what was not in the enterprise strategy … what was not in the enterprise strategy was an enterprise tax strategy and until and unless the Government is able to reassure small businesses it is with them on enterprise taxation … I think the enterprise strategy is going to have to work very hard to convince the business community that it is valuable" (Q 199). Later he commented "Yes. The CBI Taskforce Report made very clear that there is more benefit for business in Government introducing lower rates of business taxation with fewer allowances delivering an overall simpler system" (Q 201).

250. In their written evidence Oxford University wrote[91] that "the jury is still out on their effectiveness". Chas Roy-Chowdhury said that the ACCA was in favour of the EIS scheme but agreed "that a closer look needs to be had at the tax breaks for this scheme" (Q 130). Richard Stratton (LSEW) still believed that the venture capital reliefs were a good thing (Q 239), but later in his evidence he accepted that "It may be best if the tax based schemes are looked at in the light of everything else" (Q 241).

251. It was to our minds surprising and interesting that the paper published on Budget Day "Enterprise: unlocking the UK's talent" had very little to say about taxation. It was also of interest to us that there was quite a ground swell of opinion that it might be better to abandon these complex, targeted reliefs. Those who would prefer a lower rate of tax, a simpler system and fewer reliefs certainly made their case before us, while others thought that the reliefs did encourage some funds for investment into riskier projects which might not otherwise arise, and that the credit crunch would be a particularly inopportune time to withdraw them.

252. Against this background, we noted the views of officials. Mark Neale (HMT) saw it as "important to emphasise that the scheme is targeted on a specific market failure. It is aimed at easing access to finance for the small, entrepreneurial businesses that might not otherwise be able to obtain finance" (Q 376). He gave his view that "The Enterprise Investment Scheme is working well. It is targeted at a specific market failure. If we did away with it, that market failure would continue and small businesses would find it harder to get access to finance. Its total cost is not very great. It is about 160 million, whereas reducing the corporation tax rate by a penny would cost well over a billion" (Q 377).

253. We find it interesting that there was by no means general acceptance that these reliefs should remain; indeed amongst our private sector witnesses a degree of scepticism existed. However, like those witnesses, we do not know whether the net benefit of these targeted reliefs outweighs the benefits which would flow from a lower rate of tax generally. Only a review which put these tax reliefs in a wider context and had as its central objective assessing their net benefit would be able to answer that. We are firmly of the view that such an exercise would be very worthwhile.

254. We therefore recommend that a review should be carried out, putting these targeted tax reliefs in the context of other schemes targeted at small business, weighing the economic benefits of retaining them against the economic benefit of their removal, so allowing a modest contribution to a reduction in tax rates across the board and getting rid of much complexity.

The Targeting and Complexity of the Venture Capital Reliefs

255. The history of these reliefs is littered with the need to find a proper balance between reducing restrictions so far as possible, while at the same time ensuring that the funds are invested in riskier rather than safe projects: a balance between targeting and complexity. Malcolm Gammie (IFS) set out the dilemma for us "A common feature of any of those schemes is that they have to be cast around with conditions so that the policy aims of the scheme can hopefully be reflected in the detailed statutory conditions laid down" (Q 1).

256. Many of our private sector witnesses saw the schemes as too complex. Derek Allen (ICAS) thought that "In the UK we have two systems: a system for the informed and a system for the uninformed" with the schemes being too complex for the uninformed ever to venture near them (Q 132). In their written evidence ICAS wrote[92] "In practice, many professionals find the EIS intimidating and fear of making a mistake deters many from starting the process". John Cridland (CBI) saw the consultative document as "the best hope to get the EIS where it needs to be" and he commented that there was excitement about the consultation document (Q 198). Richard Baron (IoD) accepted that many of the restrictions were there for targeting reasons and if they were culled "the Revenue might find the cost of it rocketed and it got abused in all sorts of ways" (Q 202). Nevertheless, in their written evidence, the IoD saw[93] "too many traps for the unwary". The Association of Investment Companies (AIC) wrote[94] that "The specific details of the VCT scheme are complex and have been subject to various changes over recent years (which mean that individual VCTs launched in different years have to operate under slightly different rules from one another)".

257. Some of our witnesses commented on two specific aspects which were a cause for concern: the connection rules which deny relief to certain investors who are deemed to be connected with the investee company and the control rules which exclude an investee company if it is under the control of another company.

258. John Cridland (CBI) said that one of the things which frustrated business people was the connected parties criterion. He gave the example of two partners in a small planning business who had made a separate investment in the same business but had fallen foul of the rules (Q 202). Richard Stratton (LSEW) made a similar point "It is quite easy to trip up over the connection rules and become connected and lose relief on EIS investment in circumstances that you would consider to be relatively innocent" (Q 240).

259. The concern of Simon Walker (BVCA) was with the control rules which prevented small companies backed by venture capital funds from qualifying for separate EIS investment "So our argument would [be] that we would like to see all venture capital backed companies qualifying for small company tax reliefs. The fact that there is some funding from a large fund should not block that" (Q 273). He went on to explain that they had been discussing this with officials and "Actually in the last few weeks we have developed some wording about which we are talking to the Treasury almost as we speak" (Q 275).

260. When challenged that the BVCA's members seem to do very well with the rules as they are, Simon Walker (BVCA) said that he thought "there is a fundamental problem about a lack of British investment in venture capital in this country" (Q 276).

261. A more fundamental point was put to us by Michael Devereux (Oxford University) "There is evidence that small and particularly new businesses do on occasion face difficulties in raising finance for their investment" (Q 260). He expanded this "the evidence we cite here suggests that it is new businesses rather than small businesses which are particularly hit by this problem. We suggest that it would be better to target new business" (Q 262). When responding to a suggestion that these schemes were not particularly well designed, Michael Devereux responded "Not entirely. The fact that it is targeted at the problem of lack of access to finance is a good point about the scheme. The problems with it are that it is not targeted well enough to the kinds of companies which face that problem" (Q 269).

262. Responding to the general point about complexity Geoff Lloyd (HMRC) made the point that they "do have a very large number of satisfied users with the scheme as it stands. [There have been] some 14,000 companies invest since the scheme came into existence" (Q 378). He continued "We do put a lot of effort in HMRC into making sure that the rules are administered satisfactorily" and he set out the steps that they have taken including full guidance on the schemes and setting up two specialist units to deal with enquiries (Q 379).

263. Observing that they were consulting on the details of the EIS, inviting the identification of the pinch points in the scheme, Geoff Lloyd (HMRC) made the point that "a number of the conditions that apply in relation to the EIS are equivalent to conditions that apply for the Venture Capital Trusts Scheme. Therefore, we do expect to hear representations in relation to both as a result of the consultation" (Q 381).

264. In responding to the suggestion that the target company was not well defined, Mark Neale (HMT) referred to the underlying rationale which is "to target market failures and the small, entrepreneurial businesses that would otherwise struggle to gain access to finance. I have seen some of the representations from the BVCA but almost by definition, where private equity is interested in investing, the finance is there" (Q 382).

265. We recognise that the general issue of complexity, and the specific issues around being connected and control, feature in the current consultation on EIS and we are pleased to note that HMRC are entering into a substantive consultation on the details of the EIS and also, by read-across, Venture Capital Trusts.

266. We consider that the point about the target company should be explored further. We do not see why market failure might not be primarily limited to new and start-up businesses. If this were so, it would mean that the focus of EIS/VCT on all small businesses was too wide and money would be being wasted as a consequence. We therefore recommend that the consultation should be extended to include the question of the target company and that the flexibility to refine the target should be explored.

The Study by the Institute of Employment Studies, University of Sussex

267. The report by the Institute of Employment Studies, University of Sussex, into the impact of the EIS and VCTs was published by HMRC on Budget Day. The main conclusions from the University of Sussex study were that the schemes, especially the EIS, tend to be associated with general capacity building (assets and employment) but the effects remain at present quite small. On the other hand, these companies "had lower aggregate level profitability and survival rates over the period covered by the study"[95]. The authors concluded[96]:

"Overall, these results indicate that the EIS and VCT investments have a positive effect on capacity building in recipient companies. However, in material terms, these effects remain at present very small. There is some additional limited evidence of a profit enhancing effect. However, we also note that both schemes appear to be associated with differentials in performance depending on the size, age and sector of the recipient company.

future

268. The lead author of the report gave evidence before us. Marc Cowling (University of Sussex) considered that:

"In terms of the study it is very consistent with general enterprise policy … I see wider public benefits from having an EIS kind of tax incentive-based scheme, and the public benefit far exceeds the private benefit—the potential for knowledge, technology spill-overs from supportive activity ... There is a broad base of evidence that suggests that there is an equity gap … But we are still not clear where the low and upper bounds are here ... In terms of the actual findings of the report, on average 20% of VCTs and EIS invest in brand new start-ups and my guess is that it is unlikely that any more than 10% of those businesses would have started up without that supportive investment … Turning to the results, it is only the negative results on profit margins, not profit in absolute terms, so what you are getting is the classic standard economic textbook growth, short term growth profits trade-off … it is hard to keep margins up to that point while you are ploughing money into growth and the kind of uncertainty in the company … the firms are doing all the things you would want these firms to be doing … My guess is that if I followed these firms for five more years then the results would be quantitatively significant, even though they are statistically significant at the moment. So it is just where they are on the growth curve" (Q 279).

269. When asked about the University of Sussex study, some of our other private sector witnesses expressed surprise at the results; some expressed disappointment. John Cridland (CBI) said "Frankly, the results surprised us. They do not fit in with our anecdotal experience" (Q 200). Richard Stratton (LSEW) had "taken a look at the study by the University of Sussex … They reach the conclusion that if you have a tax advantage investment the company buys equipment and hires people. They go on to say that the companies do not produce any profits after doing this, as a general conclusion of this study. I suppose I was a bit disappointed by that, although not in some ways surprised because you have to bear in mind … that the period of the study was 1999 to 2005. That included the bubble on high-tech … there was a lot of investment which has since gone quite sour" (Q 239). He still thought the reliefs were a good thing despite the study (Q 239).

270. The CIOT wrote[97] that it would "have been useful to test whether behaviours had really changed with the availability of this financing, as well as whether the results of any changed behaviour are, overall, a real enhancement". The LSEW commented that the study did not reveal[98] "any better way of targeting these schemes". The AIC's view[99] was that "This research paper provides useful evidence of the impact of VCTs and supports continued public policy support for the VCT scheme".

271. Simon Walker (BVCA) was content with the University of Sussex study "I would go along with the points that were made [by Marc Cowling]. As Marc's report says, immature companies tend to have lower profitability so to some extent the rather gloomier figures could be a reflection of that rather than anything else" (Q 280). Philip Shuttleworth (BVCA) saw the question as whether the schemes are "a good use of taxpayers' money? If you look at, for example, the EIS scheme, do not forget that alongside taxpayers' money is, for example, the Business Angels' greater investment. They are pretty shrewd guys and it is not as though it is an investment which does not go through rigorous processes and rigorous due diligence and selection and I think essentially that limits the downside" (Q 280).

272. Some of our private sector witnesses were a little worried about the methodology adopted by the study. Richard Baron (IoD), commenting on the conclusions concerning lower aggregate profitability and survival rates put it this way "the cause and effect may be the other way around. It may be that if your business is marginally profitable or rather high risk given its likely profitability, you will only attract investors in and your business will only get started with the advantages of the EIS and it may be that which biases the outcome" (Q 200). John Cridland (CBI) agreed "when we tried to rationalise why the researchers found that result we came to the same conclusion, that the causal relationship may be different" (Q 200).

273. Michael Devereux (Oxford University) brought this out fully for us "I have no quarrel with their empirical evidence … Are these companies growing faster or having more investment because they have relief, or is it companies which are growing faster and want to do more investment getting the funds which this relief helps them to get? The direction of causation there is still open to doubt and needs further work" (Q 265). He amplified this for us "Yes. There is a large number of companies which have benefited from the scheme and a large number which have not. The paper compares those two to see what differences there are between them. The problem with that approach is that this is not a random set of firms. It is not random whether you get relief or whether you are part of the scheme or not" (Q 266). Asked whether he was aware of any other study which would address the points he made, Michael Devereux (Oxford University) confirmed that he was not (Q 267).

274. When these points were put to Marc Cowling (University of Sussex), he responded "Randomised experiments are great but no one will pay for them, and just randomly dishing out money is not a route government has taken in any response initiative … The fact that the panel data method used had 80,000 otherwise identical companies—same age, sector, size, et cetera—at the point of investment, and we had a time series element to it. So for those firms that were not brand new at the point of investment we had knowledge of their activity, their performance prior to investment. So that method deals with the looking across firms at a given point in time and also changes within a company over time. That method was chosen to deal with those issues" (Q 282).

275. We discussed these points with officials. Geoff Lloyd (HMRC) said that they were not "surprised by the results of the study. They do draw out the differences between the effect on performance of those companies that are supported and those that are not … by the very nature of the companies at which those reliefs are targeted, the greater risk that is inherent in those businesses will have its effect in terms of the profitability, the profit margins and the survivability of the companies. To that extent, the results are not surprising" (Q 384).

276. Commenting on the methodology adopted, Geoff Lloyd (HMRC) accepted that "there are inherent difficulties in assembling a perfect control group in relation to this sort of work. The university did a good job in identifying a control group that was as well matched as it could be with the EIS and VCT supported companies, with all factors other than the support as far as possible being eliminated" (Q 384).

277. We consider that this study into the impact of the Enterprise Investment Scheme and Venture Capital Trusts on company performance is important, particularly as it is the first of its kind, at least in Europe. However, we consider it equally important that the methodology adopted, and therefore the outcomes, should be made acceptable to most commentators.

278. We therefore recommend that the study should be re-examined to see if the criticisms from some of our private sector witnesses are justified and, if so, what can be done to gauge the effect they would have on the outcomes.

Continuing/Further Studies

279. Although the University of Sussex report was able to look at the performance of companies over more than ten years, inevitably uncertainties remained. The period considered included the dot.com bubble which certainly gave rise to increased investment and might have skewed the outcome. Richard Stratton (LSEW) had already made this point in the context of possibly explaining some of the outcomes (Q 239). That was echoed by Simon Walker (BVCA), "I do think you are absolutely right to emphasise the high-tech aspects and the problems that there are from the high-tech bust a few years ago which have marred the statistics" (Q 280).

280. Moreover, the reduction in the size of the qualifying company in 2006, when the gross assets permissible were effectively halved, in line with State Aid requirements, could also have affected the impact of the scheme. Simon Walker (BVCA) saw the reductions as leading to reduced attractiveness for investment (Q 281). And we noted earlier the view of Frank Haskew (ICAEW) that "following the changes two years ago to the gross assets test ... there is very little interest now in EIS schemes, and that the actual volume of investment going into them is quite small" (Q 130).

281. Frank Haskew (ICAEW), commenting on the present study, said "I think what it probably does show is that there probably needs to be further work done on it, and there needs to be probably more studies in relation to what I have loosely called the risk element and the reward" (Q 136).

282. Geoff Lloyd (HMRC) was comfortable with the idea of further work "We have just got the results of the study recently, and we will be looking at the database which is underlying that over the summer. As the study said, there may be a case for looking at a longer time series in order to get a better handle on the effect of the scheme. But I come back to the point about the inherent weakness in relation to demonstrating categorically cause and effect in relation to these schemes. Yes, we are looking at whether a further study can be a valuable one but we need to bear in mind it will not necessarily give us a conclusive result" (Q 386).

283. We see it as very important that a study should be carried out in which the methodology is generally accepted and which can reach a conclusion accepted by as many people as possible.

284. We recommend that HMRC should investigate the best way of continuing the study of the impact of the EIS and VCT schemes on company performance so that generally accepted conclusions will emerge as to their effectiveness.

81 Enterprise: unlocking the UK's talent published by HM Treasury and the Department for Business, Enterprise and Regulatory Reform March 2008 Back

82 Enterprise: unlocking the UK's talent published by HMT & BERR March 2008 paragraph 4.10 Back

83 The Enterprise Investment Scheme: a consultation document published by HMT and HMRC March 2008 Back

84 Study of the Impact of the Enterprise Investment Scheme (EIS) and Venture Capital Trusts (VCTs) on company performance published by HMRC as Research Report 44, March 2008 Back

85 Memorandum of Evidence by the ICAEW (Volume II p 40) Back