The Lemon Fool

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))

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.

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

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.

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.

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.

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.

Belgium has no CGT if equities only are held (slightly different rules for bonds or for funds that contain more than 10% bonds).

Hello,

I looked into this about Fifteen years ago when I lived and worked in Spain on and off. Whenever I asked Spanish or other Europeans about tax free savings and other questions to do with finance they were never sure but seemed to think that there might be a similar scheme in their country.

In reality, I never found any thing like or as generous as we have in the Uk. Even normal bank accounts, share dealing accounts etc seemed to be more opaque in terms of charges. They offer 'Free Banking' that have many charges applied. When you point out that that is then 'Not Free', they state things like "oh, that is just the maintenance charge"

It was better and cheaper for me to stay domiciled in the Uk and have my ISA etc and even buy Spanish shares from my Uk brokers.

Regards, D.L.

DelianLeague wrote:Hello,

I looked into this about Fifteen years ago when I lived and worked in Spain on and off. Whenever I asked Spanish or other Europeans about tax free savings and other questions to do with finance they were never sure but seemed to think that there might be a similar scheme in their country.

In reality, I never found any thing like or as generous as we have in the Uk. Even normal bank accounts, share dealing accounts etc seemed to be more opaque in terms of charges. They offer 'Free Banking' that have many charges applied. When you point out that that is then 'Not Free', they state things like "oh, that is just the maintenance charge"

It was better and cheaper for me to stay domiciled in the Uk and have my ISA etc and even buy Spanish shares from my Uk brokers.

Regards, D.L.

This is quite normal in Italy. They have loads of hidden charges as well as government taxes that appear, then disappear depending on which way the wind is blowing. The funniest was an old charge on simple savings accounts, i.e. to open, maintain and even to close. After the financial crisis, for about three years, they imposed a fixed tax which probably made lots of people go into the red without realising. Berlusconi, hoping to boost his 'anti-corruption' credentials, forced Swiss banks to introduce a nice fixed tax on accounts held by non-residents. Of course, the charge was so low that his friends laughed for days on their yachts.

France used to have PEPs and other things that had some advantages, but tax-free investing is quite rare these days. Probably why even Italians on low salaries often have 2nd or 3rd homes inherited from their grandparents. No council tax on primary residence, but on 2nd and 3rd homes, they pay an italian council tax, but it's still far less than in the UK. Importance of tangible assets?

Steve