I think that quite a few people here are EU citizens living in the UK and are thinking of leaving the UK because of Brexit. I understand that you can keep your ISA but cannot contribute anymore. When FT opens in other countries (do you already have an EU licence, Brexit means the UK has no more passporting rights), will there be a way to transfer an account, even if that means a GIA equivalent in the other country?
It’s all entirely speculation as Freetrade haven’t said anything about transfers between accounts officially.
But I imagine it may be possible to transfer subject to any exchange rate fees you may have to pay. Or you could withdraw and deposit in the new account. You may also need to check if you’ll be subject to paying any tax in your new country on the ISA.
As an aside, it is not just EU citizens that are thinking of leaving or have left because of brexit. So your question may have wider breadth.
However non UK countries are unlikely to recognise the ISA tax exemption and there is no cost to redemption. So your decision may be to either redeem and invest in a domestic equivalent, or keep it going but recognise realised gains for domestic tax.
I doubt passporting of financial services is relevant as an ISA is a UK only instrument. Therefore you can transfer holding to another ISA provider, but not clear you can transfer ISA holdings to an offshore share broker. It may depend upon FTs wilingness to cooperate.
From related experiences I would Imagine they make you liquidate ISA holdings to crystallise the tax consequences and then transfer a cash amount to another overseas broker.
Btw. If you do keep an isa going, consider crystallising all your gains on leaving while the funds are still tax sheltered. Don’t crystallise the losses.
What does ‘crystallising’ mean?
Crystallising or realising just means you sell to convert your paper gain to a real gain back into cash. So if you’d bought Shell and it cost you £5,000, but it’s now worth £10,000 you have a £5,000 uncrystallised or unrealised gain.
When you sell it all you crystallise/realise the £5,000 gain and you’ll now have £10,000 in cash (ignoring any charges).
This is a really important point.
I am in the same situation. I am looking to move next year and have been looking into my home country (Cyprus) in terms of taxation of income and personal estates, free allowances etc. They have about 19.5K EUR as their annual tax-free income, increasing to 20% between 19.5-60K and 35% above 60K; but in terms of tax-efficient facilities like ISA I think these are a UK-specific products?
However, closing your ISAs and transferring over in any Cypriot bank account will only incur costs from the UK Government (if any). CGTs in general are not applicable in Cyprus unless your capital gains are coming from the sale of real estate in Cyprus or abroad (20%). This is also true ONLY for financial instruments that have real estate companies as part of their holdings.
Unfortunately there is no prospect for me moving to Cyprus due to the nature of my profession so anyone with taxation knowledge in Switzerland please get in touch, as I know Switzerland is a unique case when it comes to finance and taxation.
From what I gather, with my limited knowledge of taxation systems, when it comes to investments it’s down to individual countries and not the EU as a whole. Plus - I think there are separate treaties between the UK and individual EU member states (at least for Cyprus) dealing with a number of issues including immigration and taxation as a result of Commonwealth membership.
Irrelevant Cyprus Trivia - you can jump text in italics if not interested
I am not particularly proud of my country’s dodgy, but not necessarily illegal, practises (see the latest scandal reported by Al Jazeera last month). Cyprus is a well established tax haven, especially popular with wealthy British citizens nearing retirement as well as non-EU (China, Russia) millionaires seeking EU citizenship through their “Golden Passport” scheme. All governments in Cyprus - regardless of their political beliefs - are known opportunistic predators for attracting income and the same applies for Brexit. They have rolled out a number of schemes specifically designed for Cypriot citizens who are currently non-domiciled in the island in an effort to lure income back into the country; one of them being a 10-year long scheme granting 50% deduction in taxes if you earn more than 100K and 20% if you earn less than 100K
It really depends where in Switzerland you want to move to as dependent on ‘region’ you end up paying different income tax. As you can tell, I too have extensively looked into Switzerland
This link is much better than me trying to explain it.
Over lockdown it has also become apparent that Malta is very desirable, especially if you like the Mediterranean climate:)
There is no cost on the UK side for closing an ISA, it’s a complete tax wrapper in relation to UK tax.
Yes I see you did indeed. Thanks for the info. I knew Switzerland is split in Cantons but I was hoping it had a more unified approach towards taxation hehe. I can see not. A lot of reading and planning ahead of us.
The variance in official languages (German, Italian, French) spoken locally plus local dialects of them all makes it an additional hurdle as I need to learn a new language - and no I won’t learn Romansch
I guess it’s a new challenge for all of us Europeans but maybe for the best. We (at least I) have had a good run in the UK but I am glad things are getting in line with the trade agreement - whatever that means for both sides and their citizens.
At least we are starting to know where we stand and able to start some planning for ourselves rather than being in that limbo state we’re in the last 4 years
I’m and do not intend to leave the U.K. due to Brexit … I believe the did the right thing to move away from the in reality the EU only benefitted the French and Germans, everybody else paid a very higher price to be part of that elite club.
Just imagine how bad a single Interest Rate setting can be for 27 different countries, madness.
We all feel and are Europeans nevertheless, except that we will trade differently, big deal, I can live with that ans the U.K. will prosper as a result
Move to ZUG, Glencore’s birthplace
Belgium benefitted: we were forced to restructure our economy to get in the Euro. Currency devalutions only solve symptons, not the illness. So the Euro brought good things to many countries. Greece had many structural problems that were easy. to hide in the pre-Euro era but now with a benchmark for 27 states, you could see how some countries were lagging. The UK benefitted because it could sell its services all over the EU. Freetrade could easily offer its services in 27 countries. Now it can’t without getting a new licence in the EU. Revolut has closed of its EU customers from its stock trading until they get a licence.
I also thought tht the UK would be free but in the past 4 years it became clear how much the EU countries are bound together. Leaving it is not in the interest of the country. The EU will still thrive, the UK not certainly with the government it has now.
Interesting subject. I don’t think to leave the UK, but I also have some questions in my mind.
Please correct me if I’m wrong. If you have acquired the shares, then they are your property. You can transfer this wherever you want or it is allowed. So, from that moment on, they would leave the ISA conditions to fit into the conditions of the other country. But if you sell your shares (before leave) then your capital gains would not be taxed in another country, as you obtained these gains in the UK. Is that right?
Yes, indeed Belgium benefitted the most and was able to ensure that the EU offices are based there I’ve worked for the EC in the early 2000 … and can tell you that only perhaps a handful of countries benefitted.
Funny enough it is thanks to Labour’s Gordon Brown that the U.K. never joined the Euro - just imagine how a mess Brexit would have been then!
I think that if Europeans are considering leaving Britain as a result of Brexit, then they have never really mastered the greatness of what has to offer. It will be a real shame loosing all the Europeans who moved to the U.K. from all over Europe. Many have contributed so much to the U.K. over the past 20 years.
If my memory serves me right, only U.K. tax payers can contribute to both ISAs and Pensions.
Therefore, should one leave the U.K. it is no problem at all to keep these accounts, you will NOT be able to add to it, but indeed you can hold on to them irrelevant where you move to.
There isn’t a single answer for this. Tax rules may differ in different countries so you’ll need to see what applies to you and what doesn’t in that scenario.
I don’t think this is a fair statement in either regard. The EU will probably do alright and the UK will probably do alright. the EU isn’t some magical thing, its just a giant faceless bureaucracy, there’s nothing special about it. It has its downsides as much as anything does (something Norway is apparently starting to question).
Thanks for the reply. I also believe that the UK will do alright. It’s all a matter of time.