Transferring funds and shares from European to UK broker

Early_Retire_Free

When we lived overseas (in Europe) we had a European brokerage account and, since moving back to the UK, we now have a UK account.

I would really like to consolidate everything on one platform but can't sell everything overseas (and rebuy in the UK) because it will crystallize capital gains.

Has anyone managed to do that?

Bostonerimus1

If the account is a GIA I think you'll just have to pay the CGT when you sell and move the money. Make sure you understand the applicable tax treaty and pay the right amounts of tax to the right authorities.

wmb194

Bostonerimus1 said:

If the account is a GIA I think you'll just have to pay the CGT when you sell and move the money. Make sure you understand the applicable tax treaty and pay the right amounts of tax to the right authorities.

As long as it's in specie there's no crystallisation of a gain or loss, which is what the OP's saying and asking about.

wmb194

Early_Retire_Free said:

When we lived overseas (in Europe) we had a European brokerage account and, since moving back to the UK, we now have a UK account.

I would really like to consolidate everything on one platform but can't sell everything overseas (and rebuy in the UK) because it will crystallize capital gains.

Has anyone managed to do that?

As Fineco is leaving the UK I've been looking at this myself. It'll depend on whether the broker offers what you hold but what I've found so far:

AJ Bell and Hargreaves Lansdown don't explicitly say that foreign shares cannot be transferred to them so you could try there. 

De Giro, a Netherlands broker, offers accounts in the UK and accepts transfers in and I cannot imagine it'll have a problem with my Dutch shares, so I might try here. 

Trading212 doesn't explicitly exclude anything and has a list of brokers from which it'll accept an in specie transfer (including Fineco). It offers a wide range of foreign shares. Not available to all customers at the moment but full roll-out expected 26/04/24.

https://helpcentre.trading212.com/hc/en-us/articles/16049242628381-What-are-the-supported-brokers-for-portfolio-transfers

https://helpcentre.trading212.com/hc/en-us/articles/16105401083805-Portfolio-transfers

Freetrade states that in specie transfers can only be UK or US shares.

https://freetrade.io/general-investment-account/transfer-gia

Bostonerimus1

wmb194 said:

Bostonerimus1 said:

If the account is a GIA I think you'll just have to pay the CGT when you sell and move the money. Make sure you understand the applicable tax treaty and pay the right amounts of tax to the right authorities.

As long as it's in specie there's no crystallisation of a gain or loss, which is what the OP's saying and asking about.

I does this hold for funds or just individual stocks. Will there be any cross border CGT issues when the tax in eventually due?

wmb194

Bostonerimus1 said:

wmb194 said:

Bostonerimus1 said:

If the account is a GIA I think you'll just have to pay the CGT when you sell and move the money. Make sure you understand the applicable tax treaty and pay the right amounts of tax to the right authorities.

As long as it's in specie there's no crystallisation of a gain or loss, which is what the OP's saying and asking about.

I does this hold for funds or just individual stocks. Will there be any cross border CGT issues when the tax in eventually due?

Some OEICs and, given they’re usually domiciled in either Ireland or Luxembourg, most ETFs can be sold across the EU/EEA/UK so it should be possible to transfer them. CEFs are usually listed companies. The issue with 'funds' is whether or not a broker offers them and a 'gotcha' to watch out for here is if the broker wants to e.g., convert them to another class or change it to the same ETF but listed on another exchange this might crystallise a gain or loss.

If you're really worried you can check the double taxation treaty (DTT) but being tax resident in the UK means, with investments, you usually only have to worry for the most part about UK taxation. The only thing you usually cannot avoid is foreign dividend withholding tax* and the foreign equivalent of stamp duty/SDRT when buying shares/securities.  At the risk of being out of date, not all jurisdictions in Europe have capital gains taxes anyway e.g., the Netherlands instead has an annual wealth tax and non-tax residents are exempt from this.

It actually sounds like the OP also has the option to do nothing and leave everything as is.

*The DTT will specify the rate and you may need to reclaim some proportion of it.

Bostonerimus1

wmb194 said:

Bostonerimus1 said:

wmb194 said:

Bostonerimus1 said:

If the account is a GIA I think you'll just have to pay the CGT when you sell and move the money. Make sure you understand the applicable tax treaty and pay the right amounts of tax to the right authorities.

As long as it's in specie there's no crystallisation of a gain or loss, which is what the OP's saying and asking about.

I does this hold for funds or just individual stocks. Will there be any cross border CGT issues when the tax in eventually due?

Some OEICs and, given they’re usually domiciled in either Ireland or Luxembourg, most ETFs can be sold across the EU/EEA/UK so it should be possible to transfer them. CEFs are usually listed companies. The issue with 'funds' is whether or not a broker offers them and a 'gotcha' to watch out for here is if the broker wants to e.g., convert them to another class or change it to the same ETF but listed on another exchange this might crystallise a gain or loss.

If you're really worried you can check the double taxation treaty (DTT) but being tax resident in the UK means, with investments, you usually only have to worry for the most part about UK taxation. The only thing you usually cannot avoid is foreign dividend withholding tax* and the foreign equivalent of stamp duty/SDRT when buying shares/securities.  At the risk of being out of date, not all jurisdictions in Europe have capital gains taxes anyway e.g., the Netherlands instead has an annual wealth tax and non-tax residents are exempt from this.

It actually sounds like the OP also has the option to do nothing and leave everything as is.

*The DTT will specify the rate and you may need to reclaim some proportion of it.

I was wondering if you make a cross border "in species" transfer from one broker to another will the original country want their part of the capital gains tax when it is sold? or maybe even when the transfer is made and you start with a new basis in the new country?

If you leave the funds in the original country and move yourself across a border the DTT will tell you how to divide the taxes and you can take tax credits if necessary. So that's a straight forward situation, it's the tax treatment of the securities when they move across a border that I find hard to understand.

wmb194

Bostonerimus1 said:

wmb194 said:

Bostonerimus1 said:

wmb194 said:

Bostonerimus1 said:

If the account is a GIA I think you'll just have to pay the CGT when you sell and move the money. Make sure you understand the applicable tax treaty and pay the right amounts of tax to the right authorities.

As long as it's in specie there's no crystallisation of a gain or loss, which is what the OP's saying and asking about.

I does this hold for funds or just individual stocks. Will there be any cross border CGT issues when the tax in eventually due?

Some OEICs and, given they’re usually domiciled in either Ireland or Luxembourg, most ETFs can be sold across the EU/EEA/UK so it should be possible to transfer them. CEFs are usually listed companies. The issue with 'funds' is whether or not a broker offers them and a 'gotcha' to watch out for here is if the broker wants to e.g., convert them to another class or change it to the same ETF but listed on another exchange this might crystallise a gain or loss.

If you're really worried you can check the double taxation treaty (DTT) but being tax resident in the UK means, with investments, you usually only have to worry for the most part about UK taxation. The only thing you usually cannot avoid is foreign dividend withholding tax* and the foreign equivalent of stamp duty/SDRT when buying shares/securities.  At the risk of being out of date, not all jurisdictions in Europe have capital gains taxes anyway e.g., the Netherlands instead has an annual wealth tax and non-tax residents are exempt from this.

It actually sounds like the OP also has the option to do nothing and leave everything as is.

*The DTT will specify the rate and you may need to reclaim some proportion of it.

I was wondering if you make a cross border "in species" transfer from one broker to another will the original country want their part of the capital gains tax when it is sold? or maybe even when the transfer is made and you start with a new basis in the new country?

If you leave the funds in the original country and move yourself across a border the DTT will tell you how to divide the taxes and you can take tax credits if necessary. So that's a straight forward situation, it's the tax treatment of the securities when they move across a border that I find hard to understand.

It's simple, you don't live in that country* so tax isn't due there. Liability usually ends on the day you leave. Even(!) the US doesn't care about the capital gains I make via my US domiciled broker with US listed securities because I'm classified as a non-resident alien. HMRC cares, though.

*Long enough in a year to make you tax resident anyway.

Section62

wmb194 said:

AJ Bell and Hargreaves Lansdown don't explicitly say that foreign shares cannot be transferred to them so you could try there. 

I can confirm HL were fine for transferring (in-specie) a GIA portfolio held on an EU-based platform a couple of years ago when a friend tried it.  Not rocket fast, but some of the delay was down to the sending platform.  The portfolio was a range of UK, EU and non-EU shares in various companies.  The also paid up on a transfer-in bonus they were offering at the time... which was pretty generous given the work they had to do to complete the transfer.

Hoenir

Section62 said:

wmb194 said:

AJ Bell and Hargreaves Lansdown don't explicitly say that foreign shares cannot be transferred to them so you could try there. 

I can confirm HL were fine for transferring (in-specie) a GIA portfolio held on an EU-based platform a couple of years ago when a friend tried it.

How many years ago? 

Section62

Hoenir said:

Section62 said:

wmb194 said:

AJ Bell and Hargreaves Lansdown don't explicitly say that foreign shares cannot be transferred to them so you could try there. 

I can confirm HL were fine for transferring (in-specie) a GIA portfolio held on an EU-based platform a couple of years ago when a friend tried it.

How many years ago? 

As above, "a couple"