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Tax Advantages of the AIM

Shares traded on the Alternative Investment Market (AIM) are treated as unquoted securities for most tax purposes which means that they attract many tax breaks that would not be available if the shares were fully listed.

There are also, however, occasions where the shares have the same tax treatment as quoted investments. This course is intended for those advising business seeking to attract investors as well as those advising the investors themselves.

As with many tax breaks, early planning is essential to ensure that the correct structure is in place prior to the transaction proceeding.

Course Content

Capital gains tax business taper
Business v non-business taper
The importance of trading company status
Significant non-trading activities
Problems of surplus property and surplus cash
Paper for paper takeovers involving AIM securities
Significance of shares becoming fully listed

Inheritance tax business property relief
100% business property relief for unquoted shares
Excluded activities – not wholly or mainly making or holding investments
Excepted assets rule and problems of surplus cash
Binding contracts for sale – watch shareholder agreements
Loss of relief where shares become fully listed

The Enterprise Investment Scheme
Qualifying companies - unquoted, including AIM
Qualifying trades and excluded activities
Application of money raised
Qualifying investors
The connection test
The “business angel” rule

Other tax consequences of AIM listing
Corporate venturing scheme investing in AIM companies
Venture Capital Trusts and AIM shares
EMI share options – can be quoted or unquoted company
Gifts hold over relief and AIM shares
Gift of quoted investments to charity includes AIM shares
Capital loss on unquoted shares set against income

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