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Do other European countries have schemes similar to ISAs?

Financial discussion for any financial queries for Expats
dave559
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Do other European countries have schemes similar to ISAs?

#328647

Postby dave559 » July 25th, 2020, 3:24 pm

Do other European countries have schemes similar to ISAs?

By which I mean savings or investment (Stocks and Shares) schemes which have similar tax benefits for the saver/investor.

(And related question: if one were to move elsewhere, would existing savings/investments in UK ISAs retain their tax advantages (I realise that you wouldn't be able to add additional funds))

Alaric
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Re: Do other European countries have schemes similar to ISAs?

#328650

Postby Alaric » July 25th, 2020, 3:36 pm

dave559 wrote:(And related question: if one were to move elsewhere, would existing savings/investments in UK ISAs retain their tax advantages (I realise that you wouldn't be able to add additional funds))


You wouldn't be hit by any UK taxation, but if tax resident somewhere else, you would be liable for however they tax investments, particularly what for them are non-domestic holdings. SIPPs being pension arrangements are more likely to be recognised as tax exempt by non-UK tax authorities.

dspp
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Re: Do other European countries have schemes similar to ISAs?

#328652

Postby dspp » July 25th, 2020, 3:44 pm

dave559 wrote:Do other European countries have schemes similar to ISAs?

By which I mean savings or investment (Stocks and Shares) schemes which have similar tax benefits for the saver/investor.

(And related question: if one were to move elsewhere, would existing savings/investments in UK ISAs retain their tax advantages (I realise that you wouldn't be able to add additional funds))


I have looked into this in the past, though not for a few years, however I don't think things have changed much.

1. To the best of my knowledge there are none elsewhere in Europe that are directly equivalent to ISAs. Last time I looked at it there are some that are similar to SIPPs, but I don't recall the details as I realised none would be relevant to me.

2. And as a consequence there were no transfer-across provision in the ISA area. With the SIPP equivalents, which tended to be more restricted in any case, it was well beyond my ability to understand.

I am afraid that taxation is very much an area of sovereignty being in full and rampant display. It desperately needs improving within the EU, if only to improve workforce (and retiree) mobility.

regards,
dspp

genou
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Re: Do other European countries have schemes similar to ISAs?

#328676

Postby genou » July 25th, 2020, 5:32 pm

dave559 wrote:Do other European countries have schemes similar to ISAs?

By which I mean savings or investment (Stocks and Shares) schemes which have similar tax benefits for the saver/investor.

(And related question: if one were to move elsewhere, would existing savings/investments in UK ISAs retain their tax advantages (I realise that you wouldn't be able to add additional funds))


The French have Plan d’Epargne en Actions - https://fr.wikipedia.org/wiki/Plan_d%27 ... en_actions . More restrictive than an ISA, and obviously only available if you are tax resident in France. While a UK ISA will remain tax free with HMRC , the French tax authorities will see all income/gains arising to a French tax resident as taxable.

JamesMuenchen
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Re: Do other European countries have schemes similar to ISAs?

#328758

Postby JamesMuenchen » July 26th, 2020, 9:59 am

For stocks, Germany has nothing. All gains taxed at 25%, no exceptions. Your account provider will helpfully collect this automatically, so you never get your hands on it.

There are some savings and insurance products that have some tax advantages, but generally they are lost in the fees.

TahiPanasDua
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Re: Do other European countries have schemes similar to ISAs?

#328946

Postby TahiPanasDua » July 27th, 2020, 12:53 pm

Whilst obviously not European, the Hong Kong and Singapore markets have no need of ISAs as they do not charge dividend, capital gains or inheritance taxes. You can buy stocks from all major markets there.

Of course you will get clobbered by Her Maj's assiduous tax procurers if you live in the UK. That will also apply to your original quest for ISAs in other European countries. How did you envisage getting round that?

TP2.

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Re: Do other European countries have schemes similar to ISAs?

#328952

Postby martinc » July 27th, 2020, 1:22 pm

I had a look at the French PEA (link above):

  • Max €150,000 total contributions (no annual limit)
  • European shares only (trusts/funds/ETFs) etc must have 75% elegible
  • Any withdrawal after 5 years is free of income tax BUT subject to 'social charges' (NI, seems to be about 10% for employees)
Makes an ISA look like a bargain.


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