Unchaining Investment: Barriers to US venture investment in UK digital businesses
Transcript of Unchaining Investment: Barriers to US venture investment in UK digital businesses
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7/28/2019 Unchaining Investment: Barriers to US venture investment in UK digital businesses
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1 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
1
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Ju 2013
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2 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
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3 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
cOntents
acKnOwLedgements 4
1 intrOdUctiOn 5
2 PerOrmance and investment data 7
3 the rOLe O internatiOnaL investOrs 13
4 BreaKing dOwn the POssiBLe exPLanatiOns O the UsUK gaP 17
1 less sUCCessUl vC Und managers 19
2 loWer retUrns When exiting sUCCessUl ComPanies 213 eWer good ComPanies to invest in 24
5 regULatiOn and UK digitaL startUPs 26
immigration 27
exit marKets 28
CoPyright 29
data ProteCtion and PrivaCy 30
BanKrUPtCy 32
laBoUr and emPloyment 33
tax inCentives or investment 34
taxation and other issUes 35
6 cOncLUsiOn 37
endnOtes 38
Unchaining investment
B Us u UK i bu
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4 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
acKnOwLedgements
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5 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
1 intrOdUctiOn
t UK ll l b Us vc po
vu pl UK $2.3 bllo 2012, op o $41 bllo
Us. t UK u 6 p o Us, p
20 p o populo 16 p o gdP. w u popoo
o gdP, UK u pl l l z o Us u.
ru UK u u w Us cup. nc pAtlantic Dritpub 20101, w p w 1990 bu w 2000. t w c p p w p w .
vu cp p k bu c, p p upp k cp. a w c w u cp p , w quck, u pc,2 b u 3 b c k .4
c c5 n c UK vCbck w w cp vC bck cp. W 7 p c UK c w* p, 20 p c vCbck .
t UK u k u w pcp b , uccu cu Us k. t UK eup u uzu 90 bu pcp u c bubb. a cqu pu p u b k. t cbu pc k cp b UK up.
abou po
ac Us b j b cc w p cp w pc p . t p wc cfuc Us u c UK up, w pcu cu u p cu cu Us u UK.
U uqu u u b, sc 2 cb cu UK ucp c pc, w sc 3 bf Us .
sc 4 u pb p pc p bw UK Usu. , k up p c.
W pcp Us UK u wwc UK up p. W k pcu w u cbu c . W c w u i
up , wc p 33 p c c u cp UK. o c , uc bc , u u, b cu .
*ac u w p 20 p c.
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
methOdOLOgy
t p cb qu qu u cu
UKUs pc p. , up u cp pc uk u pu p,AtlanticDrit,1 w c . t w pcp t o Pq, w upp . u p u , p p.
sc, w cuc w w 27 , up cp cc u pcp w UsUK , pc u. t w qu cp w uu p, bu w pb.
u 1: t UK u pl o UK op
2,000
7,000
1,000
US$ millions
6,000
8,000
5,000
4,000
3,000
0.00
2011
2010
2012
2007
2008
2009
2005
2006
2004
2003
2001
2002
2000
1999
1998
1997
All VC investment Internet/digital investment
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
2 PerOrmance and investment data
w p?
UK u pl ou o ou 0.1 p o gdP, op o
ou 0.2 p Us (u 2). i pobl o UK u
o ll Us, vc UK oul b $2 bllo
.
t pp pp b pp. W UK Us u gdP w c , c . a u, p w w.
u 2: vc ou p o gdP*
t c c cu UK Us u cp u(u 3), bu c . B Us UK u c pp i cp, w pcc b UK u. i c, it w c b k.UK u uc pu bc, w Us u c .
0.004
0.014
0.002
0.012
0.01
0.008
0.006
0
2010
2011
2007
2008
2009
2005
2006
2004
2003
2001
2002
2000
1999
1998
1997
UK US Continental Europe
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
u 3: aou b o
w po p?
UK u u c up cp Us u.a irr w c 20 pc p Us u p c bubb UK u (u 4).
a W U squ vu6 c c, u u Us b cku p c, b ck k p.
u ju b u i bubb, u b ac b p, bu cu b w UK (u
19902007
UK Funds
20082012
UK Funds
US Funds US Funds
Internet/Digital IT Hardware Business/Industrial
Consumer Energy Biotech/Health
Financial Services Business Services Other Industries
22%
39%45%
20%
20%
10%
7%
5%8%
18%
3%
3%
3%
3%
33%
9%
13%
12%
12%
4%
4% 4%4%
4%
14%
7%
7%
9%
16%
5%
5%
16%
6%
6%
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
pc p bw Us ). t p w w c u wc i bu, w irr UK u c i bubb b pc p bw Us cup .
u 4: a po o UK Us u pl u
15.00
20.00
5.00
10.00
25.00
30.00
35.00
5.00
0.00
33.34
13.98
UK
fund
s
USfund
s
3.87
0.53
UK
fund
s
USfund
s
15.00
20.00
5.00
10.00
25.00
30.00
40.00
35.00
5.00
0.00
19901997
37.91
13.70
UK
fund
s
USfund
s
1998200719901997 19982007
3.34
2.07
UK
fund
s
USfund
s
Net IRR (%)
All funds Internet/digital funds
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10 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
u 5: a Us UK u po b
lk pc b w , w UKUs pc p c uc 2000, pc b ac b p. t k b c uc uccu c iPo Us, c c bc i , qu uc . lk pcc b pbc u w p p u u pu. t b UK u cp w p qu Usu, b cu p p. t bu u bpc w bw p b p, p wc w p pc c cu. hw, w UK u c p w, p pc p ju u, bu p b qu (u 6).
10
0
Net IRR
(percentage)
50
40
30
20
-10
2007
2005
2006
2003
2004
2002
2001
1999
2000
1998
1997
1996
1995
UK US
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
u 6: dbuo o UK u Us u u 19902007
u 7: dbuo o u b u po
USbased funds
UKbased funds
-20 20 40-0
Excludes outside values
Net IRR (%)
USbased funds
UKbased funds
1990
1993
USbased funds
UKbased funds
1994
1997
USbased funds
UKbased funds
1998
2002
USbased funds
UKbased funds
2003
2007
Excludes outside values
15010050
Net IRR (%)
-50 0
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
u 7 b p bu b p, w c p p pc c ju bubb. sc , bu b uc (c w u u), u UKu w bw p b p.
c , Us u b p pp c b w Us u k b k w Us cuc w pcp ( cu u sc 4).
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13 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
3 the rOLe O internatiOnaLinvestOrs
g ubl po p b UK Us,
Us b o UK k? t ub o ol Us
u pl, o o po uppl ou o pl o UK
up. t lu b ol p p; po ou
o l Us k; k o Us k. so
o Us o, pll w co u, b o ll
o pul bu ol, qu o
u pof. O b p u o k, o
o ok o o o bl po o Us k.
vC ppc, p ppu pck b cp c, w ppu u k cw k. t, vC k u , u c p b b w u u ppu.
examPLes O Us investment intO the UK
hlo t p pp p w l, wp Us, w tk c p. Us w pb nw ykb U squ vu, cu WP, ac, acc P c vu. t c $30 B u 2012.
m t cu c p, b l, cbck i vu P (Us) dw Cp (UK), $62.5 C u 2012.
hul t cub w p upp cb c bu. t cp a u UKw 2010 b B C Us. t w u qu s cc l.
alo t UK puc c w cp cu
p Us iPo pp w Ceo w w b b Us. tc u acc P, m u saP ubw 2005 2008.
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14 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
hw, w u bc uk, Us bu UK eup. W c Us u u , w u c qu (u 8).
u 8: Popoo o u ou o o*
40
20
60
80
0
19902007
30%
42%
62%
20082012
26%21%
46%
UK US CE UK US CE
Percentage
*Ce = C eup. u, u w pp eup; UK Us u wpp cu.
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
w b o Us o UK?
t ub UK cp c Us bubb, bu
b c. spcc, w w p c c, w , w c (u 9).i i bu w .
u 9: nub o UK op f b u loo
t w b w uc c c b c bu, uc U squ vu w, p Us u w cp. i ucc bc cc u cp, uccu c 30 b vC p .7
W UK, w w ub bu UK c , c c c . t c cu b , b c w juc ( p w k u w Us).
200
100
Number of
Companies
600
500
700
400
300
0
2008
2006
2007
2004
2005
2012
2010
2011
2009
2003
2002
2000
2001
1999
1998
1997
1996
UK US
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
t b p b w w:
d b c u , pc , p uc, b , kp uc w
w . vu cp p b cc p cp, w w u . m UK bc c Us wu p, ( wu u fw k ub).
Our concerns about investing in UK companies are predominated by the act that
you are eight time zones and a ten or 11 hours ight away... it has to be a very, very
compelling opportunity.
Pk cu
n p p w, UK vC c b pc. t p u u ( irr) bw Us UK u
20 pc p b c bubb (u 19901997) u pc p w (u 19982007). sw c pcu b pc, wc u b uu .
u o w p p c pc c u w c qu.
Lk o l o ck pc w k c wk u c ( w) u k.
ep pl o up pc l. a pcp cp b w u , c bu, w w bu.hw, l w p p p c:
London has raised its profle as a city in the US, I think its done a good job o selling
itsel
e goo
I think (London has) a pretty good ecosystem that will be vibrant enough to help
develop the next generation o entrepreneurs and startups, because thats the one
thing which is always missing in all the European countries: having enough establishedentrepreneurs, willing investors and venture capitalists to actually take companies
through the early stage to exit.
J cl
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
4 BreaKing dOwn the POssiBLeexPLanatiOns O the UsUK gaP
U u o UK upo po o o
o b po, k o ol o UK up.
ru p puzz, u c fuc b pc, p w c w p cu b c. o pp p p p c pb cc cu b c .
t c c pb p pc p. t w p p ( p cu cb
c):
1. L uul vc u UK u cp u w Us u cp u bu ppc pucw u.
2. Lo u uul op t UK w pc u vC u iPo .
3. oo op o t UK puc w, ub u , u ck uc, u p u w.
i w p c u, wc pub w bu u, w c p b cu.
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18 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
u 10: eplo o UKUs po p
UK VC funds are
worse at investing
than US funds
Why is there a gap
in performance
between UK and
US venture
capital funds?
For successful
companies, there
are fewer exits
with good returns
There are fewer
good ventures
to invest in
UK entrepreneurs
are less able to
produce good
ventures
UK entrepreneurs
arent ambitious
enough
UK Startups
dont have the
skills to succeed
There are fewer
experienced
mentors for
companies
The networks are
less densely
connected and
less supportive
UK Startups
find it harder to
access finance
The size of the
domestic market
is smaller
The regulatory
and legislative
landscape inhibits
startup growth
The startup
enviroment is
worse for growth
Fewer
opportunities
to exit in the UK
The exits that
take place
produce worse
returns
UK VC funds make
worse strategic
choices
Choice of
investment stage
and industry leads
to poorer returns
UK VC fund
managers are less
experienced
Fundraising is
more difficult
for UK funds
UK funds are
more heavily
regulated
The characteristics
of UK fund
managers are
different
The enviroment
for VC funds
is worse
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19 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
1 Less sUccessUL vc Und managers
t p p bu UK u cp u
cc k w u. s cc b u p w pc p c ub ccc u.
u 11: UKUs po p b po*
*s b u ccc c : pc u , u pc u, u wc cp b u, z b u cp, ub cp u , w c ub ub c w u.
0.00
5.00
10.00
15.00
20.00
25.00
0.50
0.00
0.50
1.00
1.50
2.00
19941997 19982002 2003200719901993
Multiples
19941997 19982002 2003200719901993
Vintage Year Size and stage focus
UKUS gap for funds with thee same:Industry focus
Strategy variables and fund manager characteristics Share of IPO and M&A exits
-15.22
-21.49
-3.89-4.05
-1.18
-1.26
-0.22-0.16
Net IRR (%)
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
u 11 up cuc Atlantic Drit 2010 cp c . i w w u p c w w c ccu ccc u, . sp p u p p fucu u. ec
b p z UKUs u p c p, w cuuc b pp.
a o UK vc u ?B c vC u ccc , cu pc u , z u c ub, pb w u ccc c p c pc. a u 11, c c p pc p.
do UK u k o o?
i , bc cc u c k, cuu , u pc, ub cp , u wc , z , ub c, w c . a w u ccc, c p pw.
W u , c , cc u u ccc pp p p c u. 1998 2002 u, b ccu pc p ( b w), bu c z , u cu, pc pc , pc p u uuc u 2003( u p 1998).
hw, c c bu ccc vC u.8 tw c pcp UK, eup , k ppc k, w eup cu w.
s w u W C pc pu w, cp u pc cu u . o eC c , UK eup , u uc pc b u:
On the West Coast, (what) they will pay or something growing 50 per cent or more
is higher regardless o the EBITDA (earnings), as an example. I fnd that on the EastCoast, unless its over 50 per cent, theyre certainly going to want it to be EBITDA
positive or neutral. When I get to the UK, the curve looks almost linear. So I fnd that
people, and Im slightly exaggerating here, are almost willing to trade o 10 per cent
(percentage points o) growth or 10 per cent o EBITDA margin.
L h
t p ppc bu w k c, ck , pu ppc uz. t kck c ucc, c b c w c p cc k.
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21 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
s UK cp cc c w w b up u p b ,w k b bc pb. t w c w c p9 u pp vC eup
u pb up Us.
s pp w p p eup vC cu cc. t p p pc k u Us, wc k u w k kb, wc u b pc. o c, eup u c u c bu, uk Us, ckc p. a k c cc, wc w pc . t wu kck c k u bku ucc, b up c ( k p).
a w z ppp UK eupk u c , p, k p.W Us b cu b UK up, b u p Us k.
t c b u p w pc p UK vC u c z, pc . i, k p p b u qu cp wc p, cu u ubjc .
i o o u o?a pc u u b cu w u u puc uc. s pc u pc w cu , bu b . o p pb pc b w up c cu w up.
2 LOwer retUrns when exiting sUccessUL cOmPanies
t c p p pc p b b
cu uccu p cp. t u pc vC ; p , u pubc (iPo) u qu k bc , u .
a oppou o UK?acc c c pub b BvCa,10 iPo ucc uc Us eup cp c w c k ccu, u uc k Us.
ou c iPo ucc u b Us UKc u, , ucc c iPo w Us
p cp w UK p cp11
(u 13).
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22 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
u 13: s o poolo op iPO o Us UK o*
do UK op pou poo u?rc u ck qu qu k w p p bw eU Us u cp pc. t cu u b: eU u cc cp ck, cp c b u k, u up c ( c, nasdaQ p).12
C w , w UKUs pc p c ub iPo cqu u c(u 12). t u z b c u ub .
s w p c u c u UK pubc k, pc ck c b w pp c cp:
I you list on the London Stock Exchange or the AIM as a tech company, good
luck trying to get good research to cover you and basically help you build up an
institutional investment base. Youre much better o doing that in the US. You have to
replicate everything that the US has done, and by the time youre done with that you
might as well list the company in the US in the frst place. The same way i youre a
mining company, youd be silly to list in the US, youd be much better equipped listing
in London.
hu Kj
0.15
0.05
0.1
0
Percentage
Share IPO Share IPO US Share IPO UK
UK GPs US GPs
*t b u c w UK p (gP) pp bu UK bu.
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
What does cause us more angst (is) the lack o analyst coverage in Europe, so that
when you do have mature companies and you want to take them public, you get a
better reception on NASDAQ in New York, than you do in London
a UK vc
s w p iPo ccu UK, wucc w c:
I you had three decent exits, tech company IPOs on the LSE (London Stock
Exchange), the oodgates would start to open.
a Us vc
Its probably a time solved issue... the more exits that do occur in Europe the more
high net worth individuals, more entrepreneurs are going to come back into the
market and seed it weve had a ew, Skype and the likes, who have come back in
and are doing those type o things, but theres just not enough o them, not enough
big ones or us to fnd the exit partners . I youre looking at really big exits thenyeah, the US is probably the only market, but Im sure thats going to change
so J
a u vC u 88 p c Us p c cu c uccu b p c c ub c u cp, cp w 72 p c p.13 i c u nasdaQ, Us p qu k, p, qu ppu. eup cp, ck qu c, k , wc uc iPo.14
iw c nasdaQ pcu k cc,cu UK pu c k iPo Us. P k c Us pu cp cp Us:
Sometimes we require UK startups to reincorporate in the United States, but I think
thats more because eventually the hope is to have them go public on markets and
exchanges that we have more experience in and probably inuence over.
a Us vc
op w w w . s u uccuUK cp Us UK c, cp UK Pc. o , u u, UK pu wpc p cp p c w b b:
The good news is in the long run people do come back. When they come back they
bring all o that DNA back with them. I enough o it starts circling back, you can
actually jumpstart an economy or an ecosystem. Thats what were starting to see
here in the UK, there are people whove gone out to Caliornia and theyre slowly
returning back.
hu Kj
i , k b p c UKUs pc p, pcu uc p ck k c cp c cp b pcp . i cw up c Us w c pb
ppu UK.
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Barriers to Us ventUre investment in UK internet and digital BUsinesses
3 ewer gOOd cOmPanies tO invest in
t p p p u b , UK u u
qu , p cp cc qu Usp. t cu b bcu cp uccu ccc, bcu wc cp p c b w.
t c w p b w pjc. a w w c cp u c b u UK, c cp uc h skck. hw, w w pc u cp w k b uccu Uscup.
a UK up l bl o pou oo u?t c pc ck b UK pu, k . a c w bw cp k b cu, b u .
s u z Us b Us cp b bu. o c eup up w c w b c c k Us.
The number one challenge that all European startups have is that its difcult to see
the same interest in changing the world that youve seen in US entrepreneurs, where
they always think big . Its rare that someone starts a company in Europe thinking
the world is my oyster and Im going to go or the global opportunity.J cl
a pc pu k, cu w pu,w c bw Us UK up. BvCa/vusuc15 u pc c bw Us. t u c pp w u w pubcku u 35 p c Us u 15 p c eup, w , c 1995.
do UK up op o o?t wc up p cu c uc ppu
up; b c; w pp cc; cuu; u c ; cc c.
s c c k uc c b up : cc cu cc c.U uc u b w u w b.
lk b pu k, cuu pc pu u w pb c cu kk.
a ub w wu k c c p pup c p , u cuu UK.
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25 Unchaining investment
Barriers to Us ventUre investment in UK internet and digital BUsinesses
Theres more that can be done around educating UK entrepreneurs on having a less
parochial view o serving our domestic market and thats it, which then goes back to
the earlier point about British entrepreneurs tend not to be quite as ambitious.
i mk
On the west coast, i you started a business then it ailed and i you learned
something rom it then you werent a ailure, you were an experienced entrepreneur.
So I think that whatever the government can do to try and encourage that mindset
would be valuable.
d hok
sc s dJ ep u c upp p UK:
Early on in the valley, both technical and business operators who had been made
fnancially independent rom an exit event at a startup, invested back into the
ecosystem. They gave back by investing into, mentoring and going to work at the
new crop o startups. Given the tech market is much younger in the UK than in SV, weare just moving into that second phase where we have repeat entrepreneurs who are
putting back into the ecosystem.
hu Kj p cc bu p cc p:
One o the big strengths in Caliornia and Silicon Valley is there is a cadre o
people who are not ounders o businesses, and may not even be the frst ten or 20
employees, but know how to join a company either as employee number 30 or 50 or
100 and help take the company to 1,000 people, 10,000 people, 20,000 people. ... I
you happen to hit a good idea, theres no poaching ground or great talent in Europe.
New York has the same exact problem and New York is slowly building this up.
h vu pp b c bu bu, Us. t b b UK , bu , pp uccu, u ck bck bu up UK.
a p cbu up cc c. op cu p w . s c u, b, c u. o c u k, c w. hw, pc p, wc wu b b u pc .
s u w ck cp uc ck w buw b k u UK pu ppc
u cp c p.
t w w UK c p UK g p pu w pcu p eis seis*c.
In terms o earlystage capital, I just dont think theres a shortage. I really do, and I
think the UK is, rom a policy perspective, like high level as good as it gets. The US
is behind on the Founders Visa, the US is behind on Capital Gains Tax, and the US
doesnt have the same incentives on SEIS.
sul Kl
a j pc UK Us u, wc p u c.
*s ep i sc c bk w pu -up bu, cp uccu eis c .
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5 regULatiOn and UK digitaL startUPs
w ou o u Us o pp o o o
u upo UK u pl, o
up o, l ulo i l u.
t pb u u pc u c:
1. ru c w u cp u cp,wc b w c c c.
2. ru c up, c b w cu u uc b c .
3. ru c k, wc wu u c u pc
U w, c w vC u pu cc u c u. hw, pcp c u c p c p u up. c, b u ccup , bu wc w. o c, b cc bu u , kw w . o c b u pb w cp u k u u b.
ru cp up u w c pc w pk . i , w, pc up p , w p ppu p.
i pub pcp u c up cu fuc c?
C w c u w p uc k bu. t c c uc qu , bu b uc p c .
There are so ew regulations that will have a meaningul impact on the likelihoodo success o any given company. Little companies live and die on all sorts o other
things.
d hok
hw, w c u u p . o u c u c b cp, k cu u cp c:
I dont think it is that much worse (in Europe). I guess its just theres certain doors or
roadblocks that maybe dont exist in other markets that exist here. That you eel like
you have to jump through hoops, whereas maybe in the US you dont have go throughso many hoops.
m Lju
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W k pcc bu u c UK i cp,w u UK, eU. s bu c b u cp w juc, pcc cu u.
t pcu c cp eup k, wc u c cp c, w cp 27 u c.
There is no EU wide regulation or startups, you know. Startups are regulated by
national laws and regulations, i any, because there is no dierence between a normal
startup in technology and the startup o a momandpop shop, in the legal orm o
a company.
go nol
immigratiOn
Pu c pc b u cc uc bu up. Cqu, u p UK cpc ppu. ec u b UK cp w c k pu c .16 a u ubck up Us u qu w u cu b .17
i u w p b w b cucc c p UK c. t UK g uc epu v gu epu v u UK cp pc. iw p p:
You guys have been very, very supportive o startups and thats antastic. And the
act that you guys have the Entrepreneurs Visa beore the US, by like six to nine
months. I applaud what your Government has done.
J cl
n, w cc bu u c upp qu w cp, pc cc u eU:
This might be the biggest issue or our companiesthe biggest complaint is always on
the visa issues, getting a visa or an Eastern European developer. I theyre not rom
EU, its really difcult to get them in. It just takes too long and time is your enemy at
a start-up because there is someone else doing what youre doing and you have toexecute, you work six, seven days a week and pretty crazy hours. So i youre held up
hiring a python developer or six months, you could be toast.
so s
t cc ppc pc pu, pu c uc u, pb pc c buucc.18
iw u Us c , w, u w pc :
There are occasionally issues around entrepreneur visas and getting good talent intothe right country, but I think that sounds like its an equal problem on both sides o
the Atlantic.
i mk
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exit marKets
e k cuc b u u , w
p w cp p cp. e c u u iPo ck c. a u p iPok, c cu u.
a j b iPo c cu w.19 t pbb iPo w c , k c up20 c u w j (65 p c) pu pc iPo c Us c .21
ru c cp b k i Pubc o pubc qu k p u pb qu pc bck p. hw, cu p, u
c c c qu k.
W k u w pcu c b b w, c k c w p b cuc upp UK c c:
Ive got a couple o companies that were considering taking public and were having
huge debates about whether we take the company to the UK or the US... both o
them are going to end up going public in the US just because Im sure that its easier,
we eel like the markets are more open and more receptive. I dont know how much
o that is regulation but its defnitely just a sense o the way things are.
a Us vc
C w , u pu 11 p c ccpc qu b bc iPo c, b c uc pubc k u p iPo.22
t l sck ec (lse) aim k b k UK iPo, u w c cp c . t lse c uc w h gw s cb u. a cp w u 300600 , k wb cc f (u p b ).
W w h gw s w wc, w ub w wu u. iw wc u
c:
I think it tries helpully to address one aspect, but in an incomplete way... It comes
back to my same question, how are you going to get the analysts to spend their time
looking at these companies and understanding them? That said, anything that sotens
the admission criteria I think is helpul.
a UK vc
mk c bu b b w b cwu b p:
Theres probably a lot o marketing that needs to be done... in order to have the listing
markets available in Europe you need people to invest in those markets. So its aquestion o [companies] choosing to go with the US or with something (developing)
in Europe.
wll vz
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hw, p ub k c c b cp b u :
I dont even know i the Government could intervene, I think its also a matter o the
investor base becoming educated and as a result the analysts would then ollow, the
banks would ollow. Its more than just opening up the public markets.
a Us vc
case stUdy: aLrescO, a UK sOtware cOmPany seeKing a Us iPO
ac UKb w cp c u cp b UK Us u. t c uc pubc w iPo Us, w Ceo w wu b b Us.
In the last ten years, rather than the Internet dispersing expertise its actuallymade it ocus more and more on the valley in particular, and the US market. So
all the people that would ollow a company like us over the years have relocated
rom New York and theyre in the valley now, all the fnancial analysts are going
there. So its sort o a vicious circle, i the expertise and analysis o our type o
company are not there. Given the route we took and then with our backers
having US backers as well its virtually inconceivable that wed do an AIM exit.
Jo Poll, alo
cOPyright
Cp c cu w pc . a ch w , w cp p cu c, can constrain third parties wishing to access or innovate on top o this protectedknowledge or content, with potentially serious economic and social costs.a w u, bc b c , w p c bc c.
i b u uc cp w ppp , k ccu u cp; bw c cp c ; pu w cp w cu .23
rc c u ck c fb cp c pc eU. p, c w cuc cub c cp c g c w w c uc p cp cp pc w w b p cp c.24 C, cu c Us c w w p cub c w c w u c .25s w c cpb bu c pc b :
I ever there is a company in Berlin or in London, the company has to be so good that
it would make it worth clearing the copyright hurdle. And i its streaming involvingcopyright material, other materials or whatever, it has to be even better. But i we
think its a gem, then well take the risk.
J cl
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s w c w eup up juc pp up, pc k k puu w:
I think there are major chilling eects particularly in the EU, because o the patchwork
regulatory scheme thats been set up. I you want to build a product thats got a
strong consumer base in Europe its a lot more difcult to tap into the 450 million
consumers, who do still have a lot o buying power, and do buy stu.
e goo, h Lb
Even Apple have ound it really, really hard to roll out iTunes across 26 dierent
markets, its not a single market. That is due to the complexities associated with
content and rights holders on one side, and also the payment systems on the other
side.
Jo Bo
sp u uu u cp u, w
cb pb w c cp c. s cu cu c c c.
Any startup dealing with trying to develop a platorm or distributing copyrighted
content, obviously has problems, not just when you get into technical details around
data and text mining, and all those quite niche areas o copyright, and ormat shiting,
but then also around licensing and having to deal with collecting societies.
s Kll
t pb cb b c c w p w up p.
s w p ck c u u b c, c uc bu .
Were actually pretty careul about it, so we avoid businesses that provide other
peoples copyrights. We dont want to get in to that complicated structure.
m Lju
data PrOtectiOn and Privacy
ic, i pc b p u .
t w ukw ppu u cu bu,cu k . Bu u cc u c, pc b pu, qu qu u u u u pc. sk bc c b cu k. d pc u u cu pc pc b cc cc u wc p bu bu u . t p c k u p c w cp p u p p cc p:26
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Certainly running the largest video adtech company in Europe in that environment is
kind o painul without doubt. It would be great i there were privacy laws that both
protected the consumer but understood that i you put some barrier to business that
is especially bad and business will suer, but thats not how European leaders think.
J cl
t eU w b c Us pc: Us u u pc pc. rc u eU Pc ecc Cucdc 2002 w c w u c u cp cp pp $249 c p, cp w Us.27
au UK w pck u pcu b p b pbc, pc b c up cc c :
The problem is government thinking wrongly about how companies monetise the
data thats shared by consumers, and the way that consumers derive value rom data
exchange...there are seriously amazing companies that are doing great things with
data and I dont think they can survive a German style privacy regime.
e goo
m, cp eU c p uc w p 2009 d Pc dc ( ck w),wc b cp b pc c u b cc u c. eup eU ck w uc u up, p:
This EU cookie law was a pain. Advertising tech companies or about six months had
to double check this cookie stu this added riction, as they had this extra level o
checking.
hu Kj
au uc c ppc, w p w pc bu , w uc bu p.
t w cc bu ppc d Pc dc b pp.
(the Data Protection Directive) presents a lot o problems or businesses or whomdata is essentially their product. They provide a lot o their services or ree but then
use the data to build upon the service or deliver advertising or things like that [data-
driven companies] are worried about the possibility that a lot o their business is
going to be withdrawn at the click o a fnger.
s Kll
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s w bu cuc. t eup up pc u u w b p:
The right thing is or there to be an on going, active debate between a selregulated
or a selaware business community that is clearly putting the interests o consumers,
not just the business opportunities, at the heart o what theyre doing.
sul Kl
i u u kw c. i ,cp qu UK u, b uc cp k b cpw .
You have to start to think about those things rom day one and you have to think, not
about the lowest common denominator o privacy and data protection, you absolutely
rom the beginning have to think about the highest common denominator.cop Lukz
P u cp uc c, k pb ppc pc u pc k bu :
Its a bit like fnancial regulation, youre better o ollowing the regulations o the
toughest area because you know then you can do business anywhere. But the
problem is i the service is not a good service because o privacy and it becomes too
rigid, and, say, we cant do that or we cant do this, its going to be a big problem.
m Lju
BanKrUPtcy
d u u bu b c b pc c pu cuu Us eup. C w w Us , wc, pu w bu u pc, eup cu k puu. Cqu, pp k k pu p up cuu w c bu. iw b ac c cuu u k bkupc.hw, w pcu u b c UK.
W bkupc u cu p w uc u, fc , p b. rc u pu bkupcw u pu u cp28 bkupc w b p cu up.29 s (UKb) w UK bkupc u upp c u, pb cuu :
I dont think the laws a problem, I think its pretty straightorward, I think the cultures
an issue around bankruptcy.
so J
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hw, Us p pc eup bkupc w b bu:
What I would say is that I think that bankruptcy laws in Europe are much more
onerous than they are in the United States, at least by our perception. So it again
has a lot to do with this challenge o how do you build a business quickly, grow it and
shrink it. Its about being able to hire and fre people, its about being able to go out
o business without it ollowing you past the ailure o that business.
d hok
acc Us, ck Cp 11 pc b u quck buc bck c b , bu c, pc b c w Cp 11 pc.
o Us w bu w ppwk w u pcp UK:
On the downward spiral, the Government did not make it easy and then to have
these random things turn up at my house every ew months is probably not very
good marketing or enterprise in the UK honestly it leaves a very bad taste in your
mouth or the company to have totally liquidated, or the accounts to be closed, or
everything to be totally done and then or years later youre just constantly reminded
o this by the British Government in the post....It constantly reminds me o a bad
experience.
a Us vc
LaBOUr and emPLOyment
ec u k c cu w cp pc bcu c wk .30i k p b cp u p fb wkc. Us pcu p bu c cc ucc up:
We had a huge amount o difculty being agile enough, because you couldnt let all
that many people go quickly. The company, eared litigation rom (the employees)
and so it saved a ew jobs in the short run, but ultimately collapsed the company
a Us vc
t w c u b c u p eup, pcuc, UK. n, w pc b, UKu u b u Us:
Employment law in the US is ar more avourable or business owners than it is in the
UK, its slightly harder to let go o people in the UK. Youve got a lot more legislation
to ollow, but thats only with the beneft o hindsight. Whilst I was still running my
UK company, I just thought thats the way things are and it was something you dealt
with.
UK pu
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s c p u p up:
Most o the other red tape and stu really doesnt aect start-ups; theyll get away
with not having to worry about any o that stu. It becomes more o an issue as you
start employing sta and you grow, so I think or these earlystage start-ups, actually
legislation is not a limiting actor.
so J
s w c c cp u b w p:
Its a binary process, you move rom being sel-employed and its your idea to make
a commitment to run a start-up, and then all o a sudden youve got the move to
administering the PAYE scheme, which ew o these entrepreneurs would have had
any experience o and its quite burdensome.
i mk
a w pcu err (ep ru r) B k p pc.
tax incentives Or investment
t UK p c c cp, up . rc u c p : u vC u 35 p c b c pc cukk p c c ub c u cp.31
B ep i sc (eis) s ep i sc(seis)* b k uqu cp c w w p b UK p:
The entrepreneurs relie is antastic, people love that. EIS is amazing; its really been
driving investment.
so s
hw, c k eis w u b c cu Us :
Those are things which are sort o interesting, but similarly it doesnt solve the issueo showing me someone whos going to try and disrupt education, create a world
class hightech company. And i its genuine and theyre worth it, well give it a shot.
But well try to invest in the US as a frst order o priority.
J cl
t w u u w c u w:
I dont know enough about the specifcs o US angel tax breaks as opposed to the
early VC but I dont think theyre as attractive as they are in the UK. However, that
points at a much bigger problem which is a large part o earlystage angel investing
in the UK is driven by tax breaks as opposed to venture returns, which comes backto this point o thats a pretty bad thing, thats the tail wagging the dog, is peoples
investing to get a tax break as opposed to investing to see those companies grow.
i mk
*eis seis c b p w ic t , Cp g t Cp g t p.
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t UK g r&d c sme. d cp c qu c, cu w:
Weve benefted a lot rom participating in the R&D tax credit scheme which I didnt
know o beore being advised o its existence by our auditors...that was very helpul. It
is somewhat bureaucratic to justiy the rebate and its always a bit o a slog explaining
that we do R&D to HMRC. Im sure that puts o some valid claims as well as provides
nice consulting ees or the audit frms, a simpler method would go a long way to
encourage more R&D investment Im sure, but its a good oundation and HMRC does
need to prevent abuse o the scheme.
Jo Poll
s w b seis r&d c w c. ow :
Tax advantage is great ... were still educating angel investors about SEIS, never mind
teams rom Italy, to know that actually the UK is a great place to come because itseasier to get investment. So I think we do have an advantage there, I just dont think
anybody knows about it yet, outside o the UK.
so J
s p , w upp cp , b c cp up c UK,32 bupp w u eis .
taxatiOn and Other issUes
t c c wc vC pu c p cp ( p c, cp cp ). t cp b u pp cp ubjc pcu , w u k c uk pu c pc. h c w cp cw cc pu.33
a b UK, w u b cp UK u:
The taxes are actually comparable with the US once you include Caliornia state
income tax, but its things like, i they have a amily the schooling is a lot moreexpensive. They would probably complain about the healthcare because they dont
get the same benefts, although as someone whos lived in both, its better here.
Capital gains tax, Ive never heard anyone complain about CGT, except or private
equity investors.
so s
o Us UK p cp p eup:
Taxes are horribly difcult and labour laws are just downright challenging outside
o the UK in Western Europe, I mean really, really challenging. Thats probably our
biggest issue Weve ound our experiences in the UK to be positive. I mean taxand the things that were complaining about arent wholly dierent than what were
complaining in the US.
L h
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o w u pc u Us w w u, w pu Us u. t pb pcp UK p .
t u p ck p c Us eU.34 t UK p ep m ic cu upk pck p: w u c u uu, buucc. sw p pc up p ck p:
In Europe were still not too amiliar with employee share options, convertible loans
etc., but its slowly, slowly improving. I think a lot o start-ups today recognise the
need to give shares to co-ounders and probably also the next round o people that
they hire.
c Klbk
s w cu w Us cu u
u b u bw w p c pc u , cp c.
i UK, p w u ppc b cp p u pu w c bucp bc pc.
iw c pc, fc u w cu.
Us ppc, cpc w c:
Making sure that the tax regimes are reciprocal. Ideally, you want the UK to be theheadquarters and I dont have to dump something in the Antilles or somewhere else,
so that means Im going to be able to repatriate my cash, which is very difcult or us
to do in the United States, I think that would be helpul.
L h
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6 cOncLUsiOn
t po up fu o u pl po o
UK Us, ll ppo o bo UK Us o o UK
k. i u u Us l o b ok
k u, UK u u b, u ou p
po blo Us u. ho, o bo fu ,
l b po UK u pl k.
Us u p w , u w p w UK, l pcu w p c w c p u up . W c ww k c W C eup, e
C u, pc b nw yk cu b pu p uc c b p p l.
i cu p p pc bw UK Us u cp, c w w c b p.o k: i pp w, pb UK bb w pc UK u, pu b UK cp cp Us k b ub iPo k.
t cp, c u pu , w wcup p, cp u , w cuu, p,cc c , cp.
i cp p u, w u ck c cc cp.t uc c ppp p u c c pb wu, w w p up p cp ucc.
hw, u c p, p cc c. t w u w pc bu pc cu pp. a bc cu p.
t c ppc qu pcc ppc:
pcp k. t w k ccu w u, pck, k w up cp .
t qu wk u b u p. tcu:
hw u c up c k.
hw c w p w u upppup w c b pc?
C u c b u pc c u cp pc?
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endnOtes
1. l, J., Pk, y., C, l. B-Bc, a. (2010) ac d: vu cp pc UK Us.l: nesta.
2. gp, P. l, J. (2001) t vu Cp ru. Ju ecc Ppc. vu 15, nub 2,sp 2001, pp.145-168.
3. Cu, t. luk, e. (2006) t r vu Cp Bck i Pubc o: Cc, sc, mk Pw? ea 2005 mcw m Pp. ab ssrn: p://.c/ bc=604882
4. s h, t. Pu, m. (2000) t c bw puc k c : vu Cp.rw c su. 13, pp.959-984; gp, P. l, J. (2001) t vu Cp ru. Ju ecc Ppc. vu 15, nub 2, sp 2001, pp.145-168.
5. c h, m. (2013) a vC-bck . l: n.
6. W, ., (2013) vu Cp ru. B 21 b 2013. s: p://www.c.c/_c/2013/02/u-cp-u.
7. C, B., Kck, m. W, m. (2009) Bck UK vu Cp Us i: W c b? l: BvCa. ab : p://.bc.c.uk/b/cu/Bck_UK_vC__i___Us.p
8. c, w c u u uu ccc u , uc ub-ucc.
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bc.c.uk/b/cu/eup_m_rp_21J13.p10. ib.
11. n c c.
12. o, a., Puku, K., ru, m. Wk, t. (2007) vu cp eup: c p U.s. igu, g. n., K, m. Ku, r. (e.) (2007)vu Cp eup. l: e. Pp. 3-17. ab :p://.c/bc=1659311
13. BvCa d (2011) gb t vu Cp: s iPo k. ab : p://.bc.c.uk/b/cu/2011_gb_t__vu_Cp-UK.p
14. tbj, h. s, v. (2011) vu cp eup . ac: t u p. i Bu Ju.ab : p://www.buju.c/pc/b-bu/u-cp---up--c--u-p#.Uvq7rc8
15. a, U. mc, m. (2013) eup vu Cp: m c. l: BvCa. ab : p://.bc.c.uk/b/cu/eup_m_rp_21J13.p
16. l, J.d. (2006) m, ec nw Bu ac U K. s Bu ecc.
17. nvCa (2012) ac m: t ipc i epu P U.s. Cp. ava: nvCa. ab : p://www.c./.pp?p=c_c&w=c&=254&i=103
18. c t. 18 Ju 2013. UK u pu.19. BvCa d (2011) gb t vu Cp: s iPo k. l: BvCa. ab : p://.
bc.c.uk/b/cu/2011_gb_t__vu_Cp-UK.p
20. a mc 16
21. KPmg (2013) s-au iPo Wbc su Q1 2013. ab : p://www.kpu.c/b-p-u//2013/p/kp--u-p-wbc-u-q1-2013.p
22. ib.
23. h, i. hz, P. (e.) (2012) icu Pp i: a wk 21 Cu gw Jb. Bu: lb Cuc. ab : p://www.bcuc./pubc/pubc/84-cu-pp----wk--21-cu-w--jb-.
24. l, J. (2012) t ipc Cp Pc C c g vu Cp i CuCpu Cp. ab : p://www.cc./CCia//cclb//000000000642/u%20cu%20cpu%20w%20pp.p
25. Bk, C. ., (2012) l Cu: ipc Cp i scp Cu Cpu vu. ab: p://www.b.u/cu/P/.p?u=43482
26. gb, a. tuck, C. (2011) Pc i. nBer Wk Pp n. 17124. Cb ma: nBer.
27. l, J. (2012) t ipc Pc Pc C vu Cp i o a Cp.a gup. ab : p://www.up.c/c.p?=13169
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39 whO are the sUPeradOPters?
are gPs PresCriBing the latest drUgs
Nesta
1 Pu Pcl eC4a 1de
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