If you are planning a move from the UK to an EU country with an ISA, a SIPP and perhaps a taxable brokerage account, here is the honest summary before we get into detail: your ISA survives the move but loses most of its point, your SIPP keeps its UK tax status but effectively stops accepting meaningful contributions, and your general investment account may simply get closed by your platform once you update your address. None of this is a disaster. All of it is manageable if you act before you board the ferry rather than after.
I have walked several readers through this corridor, and the same pattern repeats: months spent researching removal companies, then a discovery three weeks after arriving in Spain or Germany that ISA dividends are now taxable and the UK platform wants the account closed within 60 days. Almost all of the valuable moves happen while you are still a UK tax resident. Let me take each wrapper in turn.
What happens to your ISA when you move to the EU
The UK rules are simple. You can keep your existing ISA as a non-resident, and everything inside it stays sheltered from UK tax indefinitely. What you cannot do is add new money: HMRC’s guidance says contributions must stop from the tax year after you cease UK residence, unless you are a Crown employee posted overseas.
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See the full curriculum — €147, 30-day guarantee →Here is the part that catches almost everyone. The ISA’s tax-free status is a UK concept, and your new country of residence is under no obligation to respect it. Most EU states do not. Once you are tax resident in Germany, France, Spain or Italy, the dividends and gains inside your ISA are generally taxable there under local rules, exactly as if you held the same funds in an ordinary brokerage account. Germany will want its flat-rate tax on the dividends; the Netherlands may pull the whole balance into its deemed-return regime regardless of what the ISA earned. The default assumption should be: my ISA is now just a portfolio with a British accent.
See also: Track your ETF portfolio with a free Google Sheets template.
Should you keep it or cash it in?
If there is a realistic chance you return to the UK, an existing ISA preserves years of accumulated allowances you could never rebuild in one go. If your move is permanent, you are paying fees for a shelter that no longer shelters you from the tax authority that matters, and some ISA providers refuse to serve EU residents at all, which forces the decision. I cover the wrapper mechanics in my guide to ISAs, SIPPs and UCITS ETFs for UK investors.
Your SIPP: the wrapper that travels best
Pensions are the good news. A SIPP keeps its UK tax status wherever you live: investments inside it continue to grow free of UK tax, and nothing about your move forces a transfer or a sale. Of the three wrappers, this is the one you can mostly leave alone. For more detail, see our guide: AJ Bell SIPP Review.
Two things do change. First, contributions effectively end. Once you have no UK relevant earnings, tax-relieved contributions are capped at £3,600 gross per year, and only for around five tax years after you leave. The SIPP switches from an accumulation vehicle to a preservation vehicle on the day you depart. For more detail, see our guide: IG SIPP Fees.
Second, withdrawals get more complicated. When you draw the pension as an EU resident, the double tax treaty usually gives your country of residence the taxing rights. That is frequently fine. The famous 25% tax-free lump sum, however, is a UK concept, and several EU countries tax it as ordinary income because their law has no matching category. If a large lump sum is part of your plan, country and timing can swing the outcome by tens of thousands of pounds; that is a question for a cross-border tax adviser.
A word on QROPS transfers
You will meet advisers, often commission-based, who suggest moving your SIPP into an EU-based QROPS scheme. Occasionally that makes sense. Usually it does not: fees on many QROPS products sit far above a low-cost SIPP, transfer charges have been tightened repeatedly, and the supposed benefits often evaporate under inspection. Ask anyone pushing a transfer to show the total annual cost, in writing, first.
Your taxable account: expect your UK platform to show you the door
The rudest surprise is usually the general investment account. Since Brexit, most UK platforms no longer hold the permissions to serve EU residents. When you update your address, many will restrict your account to sell-only, and some will require closure within a notice period. The details shift, so ask yours directly, and ask before you tell them you have moved rather than after.
There is a second, quieter problem. As an EU resident you fall under PRIIPs rules, so US-domiciled ETFs without a KID become unavailable, and some UK share classes get awkward too. The practical answer is to consolidate into UCITS ETFs, which work equally well on both sides of the Channel, before the move. My walkthrough on transferring ETFs out of Trading 212 shows what an in-specie transfer involves, and my comparison of the best brokers for UK investors flags which platforms remain workable once you are abroad. For more detail, see our guide: iWeb Share Dealing ISA.
Why Interactive Brokers is the default answer for UK-to-EU movers
I generally dislike one-size-fits-all broker advice, but for this specific situation one name comes up again and again: Interactive Brokers. It operates across both the UK and the EU, so an account can follow you across the border with a residency update rather than a forced sale. It accepts in-specie transfers in, offers the full UCITS ETF range, runs multi-currency accounts in sterling and euro, and converts currency at close to interbank rates, which matters when your financial life suddenly spans two currencies. I have written a full guide to Interactive Brokers for expats covering the migration process, and a broader piece on investing as an expat in Europe if your situation involves more than one move.
Ready to open an account? You can open a Interactive Brokers account directly.
The clean sequence: open the account while still UK resident, transfer your taxable holdings in-specie, then update your residency after the move. No forced selling, no gap in market exposure.
Capital gains timing: the most valuable decision of the whole move
This is where planning pays for itself. Once you are non-UK resident, you are broadly outside the scope of UK capital gains tax on shares and funds; the main exceptions are UK property and the temporary non-residence rule, which claws gains back if you return within five years. Meanwhile, your new country taxes gains you realise from the day you arrive, and several EU countries calculate the gain from your original purchase price, not the value on arrival. Move to Germany with a fund showing £80,000 of untaxed gains and sell it two years later, and German tax can apply to the whole gain, including the part that accrued while you lived in Manchester.
Your final months of UK residence are the window. Realising gains while still UK resident uses your annual exempt amount at UK CGT rates, often lower than EU rates on the same gain, and resets your cost basis before a country with no step-up starts counting. Whether to realise everything, something or nothing depends on your gain size, your destination’s rules and your return probability. The UK side is set out on HMRC’s capital gains pages; the country-specific half needs local advice. One hour of a dual-qualified adviser’s time is the best-value purchase of the entire relocation.
The three wrappers side by side
| Question | ISA | SIPP | Taxable account (GIA) |
|---|---|---|---|
| Can you keep it? | Yes, if provider allows EU residents | Yes, almost always | Often no — many platforms close or restrict |
| New contributions? | No, from the year after you leave | Capped at ~£3,600 gross, time-limited | Yes, via an expat-friendly broker |
| UK tax after the move | Still tax-free in the UK | Tax-free growth continues | Broadly no UK CGT for non-residents |
| Tax in your new EU country | Usually taxable — wrapper not recognised | Withdrawals typically taxed locally per treaty | Taxable locally, often from original cost basis |
| Action before moving | Decide keep vs. liquidate; use final allowance | Maximise contributions in final UK tax years | Transfer to a cross-border broker; review gains |
My pre-move checklist
Roughly in order, over your final six months of UK residence: use your remaining ISA and SIPP allowances while you still can. Ask every platform you use, in writing, what happens to your account when you become an EU resident. Open an account with a broker that serves both jurisdictions and move your taxable holdings in-specie. Review unrealised gains with an adviser and decide what to realise before departure. Convert toward UCITS ETFs if you still hold US-domiciled or UK-only funds; my list of global ETFs for UK investors is a sensible starting universe that remains fully available after the move. Finally, understand the split-year rules, because the exact date you cease UK residence determines which tax year your gains land in.
Related reading: Divorce ETF portfolio split europe.
What I would do
If the move looks permanent: keep the SIPP untouched, wind the ISA down calmly once local tax makes it pointless, realise the bulk of accumulated gains before departure, and run everything going forward through one cross-border broker in UCITS funds. If there is a real chance of returning within five years: keep the ISA alive and be careful about realising gains at all, because the temporary non-residence rule can drag them back into UK tax. In both cases, the SIPP is the last thing I would touch and a QROPS pitch is the first thing I would walk away from. And in every case, spend a few hundred pounds on proper cross-border advice before acting; every EU country taxes these wrappers differently, rules change, and nothing here replaces personal advice.
Frequently asked questions
Q: Can I keep my ISA if I move to an EU country?
A: Yes. UK rules let you keep an existing ISA as a non-resident and it stays free of UK tax, but you cannot contribute new money from the tax year after you leave. Your new country of residence will usually tax the income and gains inside it, because most EU states do not recognise the ISA wrapper.
Q: Do EU countries tax ISA gains and dividends?
A: In most cases, yes. Once you are tax resident in an EU country, dividends and realised gains inside your ISA are generally treated as ordinary investment income there, as if the wrapper did not exist. The exact treatment varies by country, so confirm with a local adviser.
Q: What happens to my SIPP if I move to Europe?
A: Your SIPP keeps its UK tax status and continues to grow free of UK tax. Tax-relieved contributions drop to around £3,600 gross per year, and only for a limited number of years after departure. When you draw it, the UK’s double tax treaty with your new country usually means the income is taxed where you live.
Q: Should I transfer my SIPP to a QROPS when moving to the EU?
A: Rarely. QROPS products often carry much higher fees than a low-cost SIPP, transfer rules have tightened, and the benefits apply only in narrow situations. Keep the SIPP as your default and only consider a transfer after independent, fee-based advice that spells out total annual costs.
Q: Will my UK broker close my account if I move abroad?
A: Quite possibly. Many UK platforms no longer serve EU residents since Brexit and will restrict accounts to sell-only or require closure once you update your address. Ask in writing before you move, and if the answer is bad, transfer your holdings in-specie to a broker that operates in both the UK and the EU first.
Q: Should I sell my investments before leaving the UK?
A: Often it helps to realise at least some gains while still UK resident, because non-residents largely fall outside UK capital gains tax while several EU countries tax the entire gain from your original purchase price with no step-up on arrival. The decision depends on your gain size, destination country and whether you might return within five years, so run the numbers with a cross-border adviser first.
This guide is part of our guide to moving countries with an ETF portfolio — browse the full cluster for related situations.
European UCITS/ETF investor with 11+ years building a global dividend and index portfolio, and founder of Financial Expert Class. I write every guide here from first-hand experience investing across EU brokers and tax regimes — not theory. More about me →