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VCTs - Tax Planning for 2011

By JOHN SPIERS 14/12/2010

VCTs - Tax Planning for 2011 by John Spiers

When VCT tax breaks were first introduced in 1995 they were designed to help address the equity gap for small companies. For the next ten years most of the capital raised was indeed deployed into such companies with only a small amount of leakage into lower risk ventures.

Predictably, the investment results varied widely and on balance were disappointing, although the tax relief made the net result acceptable. Investing in early stage ventures is high risk and sadly the returns do not appear to be commensurate. That's why there was an equity gap! The VCTs that pleased their shareholders were either investing mainly in well established companies (e.g. Baronsmead & Northern), technology (Foresight) or asset backed (Close).

As VCTs matured there was an increasing issue about providing an exit. Most of the underlying investments were illiquid; some investors wanted to stay in for the long run - receiving tax free income, while others wanted to head for the door. Share buybacks can deal with this but at the risk of reducing the size of the fund below an economically viable level, especially as the fixed running costs of directors and listing fees have increased sharply.

VCT managers are an inventive bunch and over the last few years new techniques have emerged that deal with most of these issues. Meanwhile, marginal tax rates have increased, thereby making the VCT tax breaks more valuable. That's why I shall be using my maximum VCT allowance again this year.

First and foremost, new investment policies have emerged that significantly reduce the risk of loss and provide funds when they are needed to offer an exit. These can take several forms. One method is to advance loans that are secured on very solid assets. This has become particularly useful following the widespread withdrawal of bank finance. Another method is to finance an activity that is self liquidating. A popular example is the bulk purchase of tickets for a sporting or leisure event such as a rock concert or season tickets for a Premier League club. This provides a cash injection for the promoter or football club and a near certainty of repayment for the VCT.

Admittedly the returns from this type of activity are modest but if you can simply get your original investment returned after five years you can generate a return in the region of 7% pa, equivalent to 14% if you pay tax at 50%.

At the same time there continue to be a number of VCTs that are designed for investors prepared to take on more risk. Long established VCTs are now able to use part of the proceeds from new share issues to finance the repurchase of old shares. This allows original investors to exit at close to net asset value while allowing the newcomers to gain a 30% tax credit from investing in a mature portfolio that is generating dividends from income and profitable realizations. This may not be a great use of tax incentives from the viewpoint of HMRC but who wants to turn down a gift horse?

This could turn out to be a record year for VCT fund raising. With marginal tax rates at their highest for over 20 years everyone is looking at ways to enhance their net investment returns. As usual we will be reviewing every VCT that is launched and offering large discounts on the standard charges. Take a look at the current VCT launches .

 
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