There are several benefits for the EIS, or Enterprise Investment Scheme, to make this an interesting...
Key Business Consultants' principal Gary Green spoke with Stakeholderz discussing the SEIS & EIS scheme and other tax relief possibilities for angel investors.
As the principal of one of the earliest SEIS tax specialist firms in the United Kingdom, formed in 2012, and having served hundreds of clients during that time, Gary's expertise with the SEIS/EIS schemes is unrivalled.
In a webinar with Stakeholderz, an equity funding platform that introduces early-stage investment opportunities to Investing Directors and executives, Gary discussed some of the key ways in which angel investors can make use of the SEIS and EIS schemes for capital gains tax relief, income tax relief, inheritance tax relief and more...
Watch the webinar in its entirety below or read on for a full transcript...
Dermot @ Stakeholderz: Good morning everybody. It’s wonderful to have you all online and many are joining us even now as we speak. It’s February the 24th, we've got a great line-up for you this morning. Gary Green, from Key Business Consultants, is regarded as one of the UK specialists in the early-stage tax area and he's going to talk to us this morning about SEIS and EIS tax investing.
There are many questions that I get asked about SEIS tax certificates and submitting my tax certificate to my accountant to get my capital and income allowances allocated in the right tax year, and so Gary is one of the great experts in the country to actually talk to about this amazing subject. Many of us think that governments don't innovate, but I actually think that the government can innovate and have done so in this particular area around tax.
Gary and I have just been chatting somewhat informally to just work out where in fact all of this came about and Gary, correct me if I'm wrong, I think the original creator of this was Kenneth Clark as he was Chancellor way back in 1994 and that was for the EIS program. Would that be correct?
Gary: Yes, we were just looking at that, weren’t we? The EIS came in in 1994 and the SEIS in 2014, which was George Osborne, wasn’t it? Remind me, you were saying…
Dermot @ Stakeholderz: Yes, George Osbourne.
Gary: He added SEIS to the EIS scheme [in 2014].
Dermot @ Stakeholderz: So, there's absolutely no doubt that this program works. It is extremely attractive for angel investors. We have just seen our first exit and the exit overall for investors in that exit was a 5X, but for those investors that got in early, it was an 18X. So, there is money to be made, but there is also tax to be paid. So, with that, I'm going to hand you over to Gary, who's going to go through some slides with you and then we'll come back to a Q&A, if you'd like to put your questions on the chat line. We'll go through those after Gary's presentation. Gary, thank you - over to you.
Gary: Thank you. So, I'm going to try and share my screen and then you'll be able to see the PowerPoint presentation from the booklet we've created about the scheme, so I'm hoping I'm hoping everyone can see this. So, we’ve got sections here - ‘What is Seed EIS?’ - mainly it's a booklet for Seed EIS because when I started my practice in 2012/2013, this was around the time that the Seed EIS was being announced in the 13/14 tax year. We sort of almost immediately said, we're going to specialize in the market for the Seed EIS, but I'll talk about the EIS scheme at the same time. There are slight differences between the two schemes.
So, ‘what is Seed EIS?’, ‘how does it work?’, ‘who is it for?’, ‘I’m an investor, what's in it for me?’, ‘I'm a small business owner, what's in it for me?’, some examples and how to get into the application. So what is Seed EIS? It’s the most generous tax-advantaged venture capital scheme ever, and what it does is it allows investors to invest in the share capital of start-up companies. In exchange for investing in the equity for shares, the investor gets back an income tax credit of 50% against their income tax bill.
What that means in this example, the maximum amount the investor can invest in a year is £100,000 per year; that would be a £50,000 of credit on your tax bill. That £100,000 investment can be spent on one company or a number of different companies. There's no minimal amounts, you can invest £1 or £5 or something like that. Also, you're allowed to elect to carry back to the previous tax year, so if you haven't invested in SEIS this tax year, which is the 2021-2022 tax year, you can invest £200,000, electing for 100,000 pounds to be in the previous tax year 2020-2021, and then the other £100,000 in this tax year. The company itself can only raise £150,000, so if you're looking to maximize that £200,000 you would be looking for at least two companies to spread your investments across.
There is a time limit of what's classed as a new company for Seed EIS and that is two years the company can only have traded for two years - no longer than two years to raise Seed EIS. What the definition is of ‘trading’ is a little bit vague. There's a bit of case law about it, but it's about whether you are undertaking enough activity to state you have started to trade. It's when you start to make sales. You don't have to have made a sale, so sometimes there is a technical issue about when you can get your claim forms and when you started to trade or not. Certainly, if you're dormant, you're not trading, but there's some technical issues on that which I'm going to address in a minute. So, that's the Seed EIS. We’re talking about £150,000 you can raise in the first two years and the investors get a 50% credit.
If you compare that with EIS, the former scheme that's been going since 1994, the investors get a 30% credit and the company can raise up to £12 million in the first seven years of trading. So, depending on what stage the companies you're looking to invest at, some will have Seed EIS available, some will only have EIS available. But if you're thinking for your companies and raising, those are the kind of dates you need to think about. So if you have any questions about that specifically about your investments, you can get in touch.
So I’ll move on. The type of tax reliefs available are, as I said, the income tax credit, the way the income tax credit works is if you've invested that, hypothetical £100,000, you get a £50,000 credit. When you file your tax return, you'd put all of your incomes on your tax return, whether it be employment income, interest income, dividend income, all those things and then it will tell you what your tax bill should be or is; and then you just apply the credit to reduce your tax payable. So, that's how the credit works.
What's important about that income tax credit and your own positions, your own tax bills, is you need to use that credit up fully. If you want to come also benefit from the other tax relief, which is no CGT when you sell those shares. It's the same for Seed EIS and EIS. When you sell those shares, there's no capital gains tax at all. That only happens as long as you use that income tax credit. So if you invested £100,000, you get a 50,000 credit under Seed EIS and you have to use that credit. If you don't, and let's say you only use 50% of that credit, you can, you've only got a tax bill of £25,000 between the two tax years because remember, we can do the carry-back. If you only claim 50% of the credit, then only 50% of the gain when you sell in the future will be exempt 50% of the gain will taxed as normal, which is either your 10% or 20% or again 10% for things like Business Asset Disposal Relief, what used to be called Entrepreneurs Relief. So that's important as well; when you're looking to invest, you should be speaking to your accountant to understand what your tax bill is and how you recover that back against the available credit.
There's another capital gains tax relief available when in the year of your investment. So if you happen to have a capital gains tax bill from another disposal of shares or a rental property or something else where you have a capital gain in this tax year, when you're looking to invest in this year, there's a CGT relief if you use those gains and you reinvest in Seed EIS or EIS. There's slightly different reliefs for both. So, let's say you make a £100,000 gain selling a property. That £100,000 gain, which for residential property will be 18% tax and at the high-rate band above that is the 28% tax, so that would be your tax exposure. But if you took that £100,000 and you invested in Seed EIS shares, the government will allow you to reduce that gain by 50%. So instead of saying you’ve made £100,000 gain, you would be saying to HMRC that you only have £50,000 taxable gain, so that's a CGT relief deduction when investing those gains into Seed EIS.
For EIS, it's different. It's not a permanent relief, it's a rollover. So, if you made £100,000 gain on a disposal and then you invested in EIS, that gain would be rolled over. When those shares are eventually sold or disposed of by selling, or if the business fails, at that point, the original tax would then become payable at that time.
How that ties in with the Business Asset Disposal Relief, or formerly Entrepreneurs Relief, when people have qualified for 10% capital gains tax on disposal, say company shares or something like that, the government has said yes, you keep that 10% rate into the future because obviously in the future, capital gains tax rates could go up, but you want to be sure that you are still eligible to claim that 10% CGT.
Those are the main reliefs at the point of investment and disposal of capital gains tax and income tax. When thinking about what year you're electing to claim your income tax credit in - remember we said we can claim it in the year of investment or the prior year - you have to look at that if you also want the capital gains tax rollover or reduction under SEIS. You can align those with a bit of tax planning. If you're looking to dispose you can get a few things lined up.
So, who's it for? It's basically any UK taxpayer. Anyone with the UK tax bill, no matter how that tax bill arises, you can invest and get credit against your income tax bill. It's not a credit against capital gains tax bill, the actual credit, so if you have capital gains tax in the same year that's treated differently, in the way I've explained it just now.
There are some excluded activities: the type of companies that are eligible for the scheme. The main thing to think about is that it has to be a trading company. It cannot be a passive income business; so, that is things like rentals, property rental or asset rentals, anything that has a royalties or dividend income stream through investments, anything passive and also professional services are not allowable like banking, accountants, lawyers, insurance, finance and things like hotels, nursing homes and home care / care homes. Those are seen as essentially passive because the property is really what people are paying for. There is a possibility, and we have had some care homes allowed for SEIS & EIS if it is short term rentals. If it's long term rentals, it's too passive. This other care home we had was for children who were only going to be staying for a couple of weeks or couple of months at a time and they said that that one was fine. So if you have any you're not sure about, you have my details on this webinar, you can send over some questions and we will discuss ways and options that you might have to raise some funds through these schemes.
So, when we talk about something like property development, investing in a builder is allowed because, that's a tradesperson. But if the business is buying, developing and selling the property, that's not allowed because you're owning the properties. Equally, if you do invest in SEIS & EIS into a property developer, the tradesperson, that company itself that you've invested in cannot provide services to an ineligible trade. For example, you can't own properties you invest in, in a builder, and then they do the building work on your properties because it's too connected.
One of the disqualifying criteria for SEIS & EIS is about connection and control of the companies. An investor can only control up to 30% of the company. When you are calculating that 30% threshold, certain people are connected with you and that is the vertical relative. So it's parents, spouses and children that cannot be counted together when calculating that 30% threshold. People who are not connected are siblings, in-laws and wider relatives. Also connected are business partners and the definition of that is someone who's actually in a business partnership, like an LLP partnership or an unincorporated partnership. So that control test of 30% can come in different forms. It can be controlling the shares, it can be exerting influence, having clauses in the shareholders’ agreement that says you can appoint or remove directors. Things like that can come across to HMRC that you have too much control, more than 30%.
One of the other things that people talk about quite a lot is whether investors can be paid investors and the answer is yes, but there is a certain order at which you would have to do three things. One is the timing of being an investor, one is the timing of being added as a director and the timing of when you actually take paid remuneration through the company.
As long as you become a director before you take a salary, you would be able to be paid a salary for director services or employment services. It’s very important to get that checked with an accountant first if you're looking to be a paid investor. So, that is separate from a contract for services. If you have, let's say a marketing company or a consultancy company and you were going to provide services to this company, HMRC says that's fine. You can provide services from your other businesses, but you cannot be a paid employee unless you are also a director. So just a bit of care needs to be taken around that aspect.
So I've gone through what the tax reliefs are for you: Seed EIS is a 50% credit, EIS is a 30% credit against your tax bill. The CGT reliefs as well. And I think we'll talk about the other two reliefs, which is loss relief and inheritance tax.
If the business fails, you can claim the remaining unrelieved amount as an income tax loss. So, in Seed EIS, that example, £100,000 was invested, 50,000 credit. I claimed that credit fully, so I have an investment really that's cost me £50,000. If that business fails, I can claim the remaining 50% as an income tax loss against my income tax bill in the year which that investment failed. So for EIS. £100,000 invested, £30,000 credit. I've got £70,000, which has not been relieved and again I can claim that £70,000 as an income tax loss. That's different from a reduction in your tax bill, that the income tax credit is, it reduces your taxable income. So, let's say I have £200,000 pounds of income and now I'm going to claim £70,000 as a loss. It means I'm only going to get taxed on £130,000, not the full £200,000 and then my effective tax rate, which is going to be that blended 40% to 45%, my effective tax rate is my tax relief on that. There is a £50,000 general cap on income tax loss that anyone can claim in a tax year anyway, so you just have to be aware of that.
The benefit of this scheme is that most people, most of the times, if you invest in shares, those shares will get you a capital loss. So it’s obviously less easy to claim those losses, unless you have other capital gains, sometimes capital losses can go on for quite a long time before you use them up, if at all. The benefit of this scheme is that you can claim it as an income tax loss, so it's more flexible. There's also opportunities to carry back those losses or elect for those losses to be recognised in the previous two years. If you can't use those losses fully, you can use those as carry-forward as well. So if you're in a situation of loss relief, there's some small technical points, how to claim that on your tax term, things like that, but that's largely how that relief works.
So for inheritance tax, there is a relief called Business Asset Relief. If someone does die with business assets that are qualifying - mainly again trading companies, not investment companies, SEIS/EIS qualifying companies will qualify for that relief – it just means that those shares would go down to the beneficiaries tax-free. So, as long as you hold onto the shares for two years, they qualify for inheritance tax relief and as long as you hold onto the SEIS & EIS shares for three years, then the tax relief is permanent. It means that you can't sell your shares within three years of making the investment.
So for Seed EIS, the money goes into the bank account first, the shares are issued once the money has been received, that's quite important. EIS cannot be done on the same day as SEIS, there must be at least one clear day difference. But the company can receive £150,000 plus more money straight away and can issue the SEIS and EIS one day apart.
The Seed EIS funds need to be spent within three years and the EIS funds need to be spent within two years. You can't just sit on those. So when the money goes in and when you can claim the claim forms is, for Seed EIS, you can go to HMRC and ask for the claim forms. The sooner of having traded for four months, which I talked about before, what the definition of trade can sometimes be a little bit vague. But when you trade it for four months or you spend 70% of the funds, then you can go to HMRC and apply to get those claim forms.
For EIS, you have to have traded for four months before you can get the EIS relief. So it's important if you're thinking we have a lead time before we're going to start to trade. For example, before you're going to open a restaurant or something like that. Those four months can be important. For SEIS, the tax point for that three-year holding period is the date the shares are issued. So, the money can go in now, the shares can be issued now, that's your tax point, count 3 years forward. For EIS, it's different. The three-year holding period will only start when you started to trade. So, if we get the money now, but we don't start to trade for four months, then my three-holding period would be three years and four months from today's date. So that can be important about holding on to those shares.
A common question is ‘what happens if the business fails within the three-year period?’ or ‘if the business gets bought out within three years?’. If the business fails within the three years, you still get loss relief, you still keep your income tax relief. If the business is bought or you've disposed of those shares, then you will lose that income tax relief that you already had. You would have to go back and amend your tax return that you claim the income tax relief on and the tax will be due at the original date with a little bit of interest. So if a business is looking to sell within those three years, buyout or something like that, you would want to discuss maybe going across in the buyout and getting shares in the new company rather than actual disposing of your shares through that purchase. So those are some things to think about.
There is something I’ll mention as well: HMRC has an approval process. It's not really an approval actually – I’ve used the wrong word - it's something called the advanced assurance process. It's not a registration, it's not an approval, it's not a certification or anything like that. It's completely voluntary. But what you do is you go to HMRC and you say this is my business plan, this is my forecast. The forecast will have to justify how much money you're seeking to raise and how that's going to be spent, so there has to be a need for the money, not we're making money and we're going to continue making good money and we just want to get tax relief for the investors, they don't really want to perform those kinds of things.
But you give a business plan, a forecast, people you're actively talking about investing with, because they want to see that you're active and not just that you want the advanced assurance for certain reasons. You explain how the funds are going to be spent, you send them any amended articles or a shareholders’ agreement that you're discussing. You make the application online. It's not terribly expensive. We charge a few £100 for both applications, SEIS and EIS, and you can get HMRC to review everything you're doing. They'll come back and say OK, based on what you've told us, you're OK. You should be qualifying and you just have to stick to all the other scheme rules. And the benefit of that is you can go to your investors and you can tell them that you've told HMRC what you're doing and they're happy with that. If there's uncertainty about what you're doing, you can get the advanced insurance process.
The scheme itself, you have to do a number of things at Companies House like issuing the shares properly, creating a register of members - the shares register - that goes off to HMRC when you're able to get the claim forms, which I explained before. And if you haven't got the advanced assurance already, you would have to send that same information at the time of applying for the claim forms. So, if you've done the advanced assurance normally, the claim form process is quite quick. Advanced assurance, at the moment, we're getting them back in five to ten days. The claim forms, similarly, maybe a little bit longer, 10 to 20 days. So in terms of timing for the investors, you need to be thinking around the end of the tax year, 5th April, because you might want to invest in this year or the prior year or both and so 5th April is the end of the tax year; the tax point is the date that the shares are issued.
So, about Stakeholderz, they themselves have a fundraising platform. I’m not sure if I'm right in saying it's a a crowdfunding seedfunding Series A type fundraising platform. You're obviously all registered, so they have they have these deals on their website that you can check out and you can then try to match to your own personal circumstances knowing and understanding the reliefs available. This one is Revoola and it says that there’s EIS available and that means that you can understand the difference between Seed EIS & EIS. But if you have any questions about your circumstances, maximising your tax relief, you can just send me a message and we can talk confidentially.
Dermot @ Stakeholderz: Very good. Alright, well - sorry, you’ve got a couple more slides, yes?
Gary: No, I think maybe that's it. There’s some examples in the different type of scenarios, how those tax rates work. Oh! Actually, yes, just the final one. So, a recent addition to the scheme is this risk to capital condition. They brought this in about two years ago and it's because some of the investments were just a little bit too easy for people to get the tax relief. So they brought in this risk capital condition that said there has to be a genuine risk, but it's subjective, it's not objective. So basically, if the agent thinks it's a little bit too cosy and you're not presenting any risk, they will push back on that. So, something to look up on is that risk capital condition. Sometimes things like restaurants, they have to have a premises, so owning a property is seen as de-risking because you still have that asset, whereas a short-term lease they will see that as a normal risk business venture. So think about looking into the risk capital condition because that can also be important in how you present your business plan and your forecast. If it's too optimistic, HMRC will say, ‘but why do you need the money then for the investment?’ So there's that balancing act. That's it from me.
Dermot @ Stakeholderz: Very good. Well done. If you'd like to take the slides down, we can head to some questions. I’d actually quite like to lead off from that because we have a format and stakeholders come to the market base to provide equity funding and senior executive talent to technology businesses. But the investing director format, which is sort of one that you covered, and you suggested that the timing of things about investors drawing salaries, becoming directors, is really important to get right. What more could you add to that? I mean, you were very clear when you said it, but I'm sure there's other stuff that we should be aware of.
Gary: Yeah. So the restriction is that you can't basically, offer the shares to your employees. There's different share schemes for employees, EMI and stuff like that, and it's just preventing people saying, “oh, I've got my employee here, why don't I get them to invest in my business? I'm going to give them a bonus so that they get that tax bill, and then they write it off by investing in my business.” They say it's not for employees.
Dermot @ Stakeholderz: OK. So that's basically the rule of thumb if a director is an employee. You don't qualify. And you've done it ahead of time.
Gary: Yeah, correct. But what they say is if you are an angel investor, which they say is if you are a director before taking a remuneration, they'll allow that. So the basic idea is not for employees, but if someone invests in my business and then says, oh, I actually want to take a salary because I want to help out and do some services; become a director first and then you can take the salary, so the ordering is important.
Dermot @ Stakeholderz: Very good. Thank you. We'll head to the chat area now. Did you touch on what is the CGT treatment when EIS shares are sold before three years? I think you did actually.
Dermot @ Stakeholderz: Anything more to that?
Gary: Yeah. So it's generally 2 scenarios. One is a disposal, like a buyout, and one is if the business fails. If the business fails HMRC says, “that's fine, we’ll still keep the tax relief” and then you get that loss relief. If the business is bought out or you sell your shares, you will lose that relief. There's two situations where that doesn't happen, it's through divorces and gifting shares to a spouse, I think the tax relief remains. And through probate when there's a death, the tax relief is still in place.
Dermot @ Stakeholderz: That's good. Thank you. So Nicholas Lenz has asked, what about the following situation? Year one, an investor invests £100,000 in EIS investment and claims 30% income tax. Year two, the company becomes insolvent and is sold, but no value is realised for investors. So can you then still claim loss relief on the 70% that remains?
Gary: Yeah, so there is a way to do this. We had a similar situation where someone's business hadn't gone into liquidation but the accountants were saying it's only a matter of time before the company fails and the investor taxpayer put on their tax return to claim what they call negligible value loss relief, basically saying it's worthless, and HMRC came back and they said no, we're not going to allow that and so we came up with the idea that what you would do in that situation is you would basically surrender your shares back to the company and just say I don't want them anymore. And then of course you would get to tell HMRC I've now made that loss. So yes, if it was bought, you run the risk that you sold those shares, but there's that work around.
Dermot @ Stakeholderz: OK. Thank you for that. Richard Martin has asked is it possible to issue different classes of voting shares - EGB shares - which participate above a maximum, above a certain valutation?
Gary: Yes. So you can have different classes of shares. Obviously, that's quite routine when you go into seed funding series A, B, C etc. So HMRC just want to look at those new class shares and the amended articles, shareholders’ agreement, to make sure there's no preference. So you can't prefer the SEIS & the EIS investors. You can't say I'm going to give you your dividends first, I'm going to buy those shares etc, I'll pay you back even after the three-year period and things like that. But you can have different classes that are totally legitimate. It is possible to even say I'm going to pay class fee in in a 95-to-5% split first and then I'm going to change it around in a different format. We've seen those being approved as well. So it's just a matter of checking with someone who knows about SEIS & EIS. If you're not sure, you can keep sending advanced assurance anyway. So we talked about the advanced assurance as a voluntary thing to begin with, if you make a change like create a new class of shares, you can send that to HMRC in a new advanced assurance and say is that OK? If they come back and say no, then you know you need to change that.
Dermot @ Stakeholderz: It's very useful, so I think if anyone’s questions haven't been answered, you'll pick them up maybe after this event won't you? Because we can send them to you. There's one that's come back asked by Calvin Harris and I think we've actually answered it, but I'm not sure and obviously he's kindly asked the question and we must get him his answer, so perhaps we could circle back on that if necessary. We have actually got one more question in John Barnes. So is there any disadvantage in claiming relief as soon as the SEIS or EIS paperwork comes through?
Gary: Yes. So I spoke before about when you can get the tax claim form from HMRC. For Seed EIS, spent 70% of the funds for traded for 4 months. EIS, you have to be trading for four months. So as soon as you get those claim forms, obviously it's just in your benefit to put that on your tax return as soon as possible. So, if I invest now when I get my tax claim form, it's in the 2021-2022 tax year. I'm not going to file my tax turn until after the 5th of April, so I can either wait and then reduce my tax bill when I'm paying on 31st January 2023, or I can elect to carry-back if I have the tax bill there and I haven't used up my allowance, I can elect to carry that back. Then obviously if I filed my tax return and paid the tax bill already, I'll amend that tax return with credit and I'll get a refund plus some interest, so it makes sense to try and claim that as soon as possible.
Dermot @ Stakeholderz: Very good. Thank you. Another question here - do other countries have similar schemes or is this unique still to the UK? I think I know the answer to this, but over to you.
Gary: Yeah, I think a lot of the tax authorities across the world do keep an eye on what other countries are doing. I think it's unique in the sense with the rules that we have here, I think I'm pretty sure they have a similar scheme in the US and maybe it's industry-specific, like they might say you can do that if you invest in films and those kind of industries. I think there are some in Europe, in France and Germany, but it's not quite the same. One thing I just touched upon as well is that risk to capital condition that we were talking about before. There's two threads to it; one is the risk and the other one is how long you intend your business to go for.
So, this one's a bit of a funny one, but talking about the film industry and why they brought in this condition is because if someone is a good film producer, what they're doing is they're raising £150,000 for SEIS. They're raising £12million under EIS with all these big investors you've probably seen in the news and creating one movie, you know, hiring the top talents in Hollywood, making a ton of money and going, “right, done that one” and getting no CGT to close that business down. And then he said, “well, let's do that again.” So those series of movies and tax reliefs is what they said “no, we're not going to support that”. What they will support is if that one company is going to continue making movies, movies, movies, they'll support that one company. You can't just keep rehashing the same thing and keep getting the tax relief. So we have clients at the moment who say I've got an idea for a couple of products. I want to raise £100,000-£150,000 to make one product and then if that's successful I want to go and make the second or third. HMRC are pushing back on that and saying well, we can't see the longevity if you fail in this one first product, you're not going to continue. So how do you meet that risk capital condition that you are looking for long term growth? So that can sometimes be difficult, but that shows that it's important about your business plan and your forecast to show that you, as the business owner, are going to continue the business, even if that investment comes in and doesn't produce the results, you're still going to carry on. So, that's something we're seeing a lot more at the moment.
Dermot @ Stakeholderz: Gary, that’s terrific. Mindful of time. I think it sort of allows me really to begin to wind up this webinar. There are a number of questions we'd love to ask the audience about your interest in this event, how we can improve it or one or two things we'd love to tell you about Stakeholderz and get a point from you back on. Things like Syndicate, we do from time to time seek investment ourselves, so that might be useful for you to know. But it does occur to me that now, at this stage in the tax year, there are some excellent ventures on our platform. You'd again have a look at and Revoola was mentioned earlier.
So, if you have got a tax issue, you've probably got one of the world's - and certainly the country's - most advanced experts facing you on the screen today. Gary, thank you so much for your input. You've answered the questions with an amazing amount of depth, knowledge and insight.