Appendix 1: International Comparison of Investment Incentives
Jurisdiction
Type of Incentive
Tax Relief/Benefit Level 30% investment tax credit
Eligibility Criteria
Canada
Proposed National Investment Tax Credit (NITC) Seed Enterprise Investment Scheme (SEIS), Enterprise Investment Scheme (EIS) Qualified Small Business Stock (QSBS) exemption Angel's Law (tax credits for angel investors); Public-Private Co-Investment (Israel Innovation Authority)
Canadian-controlled private corporations (CCPCs) focused on R&D and innovation
United Kingdom
SEIS: 50% tax relief; EIS: 30% tax relief
Early-stage startups, UK resident investors
United States
Exclusion of up to $10 million in
Investments in qualified small businesses; must hold stock for at least 5 years Early-stage R&D/high-tech startups; qualifying private investors and local/international co-investors
capital gains (federal tax)
Israel
Tax credit equal to capital gains tax rate on investment (up to ILS 4 million); matching grants and co-investment structures No tax on reinvested profits
Estonia
Zero corporate tax on reinvested profits
All Estonian businesses reinvesting profits domestically
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