What are the rules of EIS investments?

what are the rules of eis investments scaled

The Enterprise Investment Scheme (EIS) is designed to encourage private investment into growing British companies, by offering attractive tax reliefs.

It is one of the UK Government’s flagship policies for supporting British enterprise, stimulating approximately £1bn of private investment each year. For anyone considering investing in to the EIS scheme, there are a number of EIS rules they need to take into consideration.

What are the rules of EIS investments?

EIS offers investors a multitude of tax reliefs. However, there are some important EIS investment rules that both investors, and the founders of the companies themselves need to adhere to. Below are some of the most frequently asked questions around EIS scheme rules:

How long do I need to hold EIS shares?
  • There are two key time frames that EIS investors need to be aware of that fall within the EIS rules for investors:
    • In order to retain income tax reliefs, the EIS shares need to be held for a minimum of three years, from the date of ownership. It is possible that the shares in the business could be disposed of within this period due to the company being sold, and should this eventuality arise, the original tax relief provided by HMRC can be clawed back.
    • In order for the EIS qualifying shares to benefit from Business Relief, they need to be held for a minimum of 2 years from the date of purchase, and still need to be held on the death of the owner. If this happens, the value of the shares will be exempt from IHT. However, should the owner die within the two year holding period, the value of the shares will form part of his/her estate for IHT purposes.
  • There is often confusion between the minimum holding periods listed above, and the lifecycle of EIS investments. Although the minimum holding period is three years, in reality an investor should expect to hold EIS shares for at least 5-7 years, and in some cases longer.
 
Can an Investor be a director?
  • EIS rules are not intended to discourage investors who would like to become directors of the company (or a subsidiary of the company) they invest in. Quite often, investors have business expertise that can benefit the investee company. These investors are often known as “business angels”. Business angels are allowed to qualify for income tax relief despite the fact that they receive payment for their services. However, EIS scheme rules around this subject are strict, and only apply where:
    • The only way the individual is connected with the company following investment, is in the role of a director, who receives, or is entitled to receive remuneration, and at the time the shares are issued, the director in question has never before been connected with the company in any way.
    • Remuneration, for this purpose includes items such as benefits, and remuneration must be reasonable in amount.
 
Can I invest in my own EIS company?
  • HMRC has strict EIS rules for investors looking to invest into their own company. The investor cannot be “connected” to the company. An individual is deemed as having a connection with the issuing company if he or she, or any associate of them is:
    • An employee
    • A partner, or an employee of a partner
    • A director (except from where a director receives, or is entitled to receive, remuneration)
    • A director of a company which is a partner of the company, or of any company which is at any time a subsidiary of that company
    • An individual is connected with a company if he or she, whether alone or with an associate directly or indirectly possesses or is entitled to acquire more than 30% of the ordinary share capital of the company or any subsidiary.
 
Can family invest in EIS?
  • Another EIS investment rule is the connected parties rule. This restricts the ability of certain family members from investing into a company via EIS. Relatives, under connected party rules are defined as spouses and civil partners, parents and grandparents, children and grandchildren.
  • This means that there is some scope for investment by a limited number of family members – brothers and sisters, aunts and uncles, nephews and nieces, unmarried partners and in-laws are all free to invest, and benefit from the EIS tax reliefs.
 
Can companies invest in EIS?
  • Companies can invest into EIS qualifying companies. However, EIS scheme rules stipulate that the associated tax reliefs are only available to individuals.
  • The tax treatment between a corporate and individual application is different – if a company makes a corporate application, they will be able to do so without any initial liability to tax, and it is a good way of extracting accrued capital from the balance sheet. However, as such an application benefits the company, the underlying investors will not benefit from the associated tax reliefs afforded to individual investors. Therefore, it may be beneficial to determine the overriding objectives of the investment, and whether individual income tax relief, EIS CGT deferral, tax-free gains, and IHT relief are a reason for looking at an investment of this type. If it is, it may be beneficial to extract individually, pay the tax, then claim back and benefit from all the other EIS tax benefits.

 

Estimated reading time: 2 min

 

Due to the potential for losses, the Financial Conduct Authority (FCA) considers this investment to be high risk.

What are the key risks?

  1. You could lose all the money you invest
    1. If the business you invest in fails, you are likely to lose 100% of the money you invested. Most start-up businesses fail.
  2. You are unlikely to be protected if something goes wrong
    1. Protection from the Financial Services Compensation Scheme (FSCS), in relation to claims against failed regulated firms, does not cover poor investment performance. Try the FSCS investment protection checker here.
    2. Protection from the Financial Ombudsman Service (FOS) does not cover poor investment performance. If you have a complaint against an FCA-regulated firm, FOS may be able to consider it. Learn more about FOS protection here.
  3. You won’t get your money back quickly
    1. Even if the business you invest in is successful, it may take several years to get your money back. You are unlikely to be able to sell your investment early.
    2. The most likely way to get your money back is if the business is bought by another business or lists its shares on an exchange such as the London Stock Exchange. These events are not common.
    3. If you are investing in a start-up business, you should not expect to get your money back through dividends. Start-up businesses rarely pay these.
  4. Don’t put all your eggs in one basket
    1. Putting all your money into a single business or type of investment for example, is risky. Spreading your money across different investments makes you less dependent on any one to do well.
    2. A good rule of thumb is not to invest more than 10% of your money in high-risk investments. https://www.fca.org.uk/investsmart/5-questions-ask-you-invest
  5. The value of your investment can be reduced
    1. The percentage of the business that you own will decrease if the business issues more shares. This could mean that the value of your investment reduces, depending on how much the business grows. Most start-up businesses issue multiple rounds of shares.
    2. These new shares could have additional rights that your shares don’t have, such as the right to receive a fixed dividend, which could further reduce your chances of getting a return on your investment.

 

If you are interested in learning more about how to protect yourself, visit the FCA’s website here.