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Post by andrewcfa on Mar 21, 2017 9:43:33 GMT
We wrote a guide to the Innovative Finance ISA that would be a good read for both new and experienced lenders as an introduction to the IF-ISA. You can download the guide here: crowdforangels.com/ultimate-innovation-finance-ISA-guide.pdf (no registration or email required) As a declared interest, I am the CMO from Crowd for Angels.  |
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ilmoro
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'Wondering which of the bu***rs to blame, and watching for pigs on the wing.' - Pink Floyd
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Post by ilmoro on Mar 21, 2017 15:01:55 GMT
We wrote a guide to the Innovative Finance ISA that would be a good read for both new and experienced lenders as an introduction to the IF-ISA. You can download the guide here: bit.ly/2nMvzh1 (no registration or email required) As a declared interest, I am the CMO from Crowd for Angels. The Ultimate Guide ... thats a bold claim. Unfortunately my copy seems to be missing the penultimate pages where it discusses the ability to transfer ISA and the concept of 'flexible' ISA.  Statement at the bottom of section 3 is inaccurate. You can open more than one IFISA in a tax year but cant subcribe new money to more than one, you need to transfer exisiting ISA funds.
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ozaz
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Post by ozaz on May 6, 2017 12:58:45 GMT
You can open more than one IFISA in a tax year but cant subcribe new money to more than one, you need to transfer exisiting ISA funds. I hope this is the case (I would like to open 3-4 IFISAs this tax year and transfer some money to each from a previous year cash ISA). However, I can't find a statement on HMRCs website saying you are allowed to open more than one ISA of a given type in a given tax year. Are you basing this on absence of a statement saying this is not allowed, or have you had it confirmed from an authoritative source that it is allowed? Thanks
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rogerbu
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Post by rogerbu on May 6, 2017 13:15:11 GMT
You can open more than one IFISA in a tax year but cant subcribe new money to more than one, you need to transfer exisiting ISA funds. I hope this is the case (I would like to open 3-4 IFISAs this tax year and transfer some money to each from a previous year cash ISA). However, I can't find a statement on HMRCs website saying you are allowed to open more than one ISA of a given type in a given tax year. Are you basing this on absence of a statement saying this is not allowed, or have you had it confirmed from an authoritative source that it is allowed? Thanks These are the same rules for IF, Cash & S&S ISAs. You can open more than 1 ISA (of each type) in any one year, but can only subscribe to 1 of each type. The ISAs opened but not subscribed too, may receive previous years contributions from any type of ISA (IF, Cash or S&S) without breaking HMRC's rule of subscribing to only 1 ISA of each type in a tax year.
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ozaz
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Post by ozaz on May 6, 2017 13:22:55 GMT
rogerbu, I understand you are only allowed to subscribe to one of each type in a given tax year. I also understanding there is no limit to transfers of previous-year ISA funds between ISAs. What is not clear to me is whether you are allowed to open more than one of each type in each tax year (even if those ISAs are not subscribed to). Are you basing your opinion (that you are allowed to do this) on lack of statement from HMRC that it is not allowed, or do you have confirmation that it is allowed? Thanks
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rogerbu
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Post by rogerbu on May 6, 2017 15:44:47 GMT
rogerbu , I understand you are only allowed to subscribe to one of each type in a given tax year. I also understanding there is no limit to transfers of previous-year ISA funds between ISAs. What is not clear to me is whether you are allowed to open more than one of each type in each tax year (even if those ISAs are not subscribed to). Are you basing your opinion (that you are allowed to do this) on lack of statement from HMRC that it is not allowed, or do you have confirmation that it is allowed? Thanks As said - The transfer rules are the same for IF, Cash & S&S ISAs. I am basing my opinion on two things. 1. I have done this several times for S&S/Cash ISAs. Opened a 2nd ISA, not subscribed to it, but sent previous year's subscriptions to it. 2. I confirmed this with Hargreaves Landsown before using them as a destination for previous years subscriptions - or part thereof
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IFISAcava
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Post by IFISAcava on May 6, 2017 16:01:12 GMT
rogerbu , I understand you are only allowed to subscribe to one of each type in a given tax year. I also understanding there is no limit to transfers of previous-year ISA funds between ISAs. What is not clear to me is whether you are allowed to open more than one of each type in each tax year (even if those ISAs are not subscribed to). Are you basing your opinion (that you are allowed to do this) on lack of statement from HMRC that it is not allowed, or do you have confirmation that it is allowed? Thanks As said - The transfer rules are the same for IF, Cash & S&S ISAs. I am basing my opinion on two things. 1. I have done this several times for S&S/Cash ISAs. Opened a 2nd ISA, not subscribed to it, but sent previous year's subscriptions to it. 2. I confirmed this with Hargreaves Landsown before using them as a destination for previous years subscriptions - or part thereof You can definitely open as many IFISAs as you want this tax year, but can only subscribe new cash to one and transfer previous years ISA cash (of any sort) to any or all of the rest. You can also move newly subscribed ISA cash to another IFISA in the same year, but must move it completely so that you only have new cash in one IFISA at any given time.
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IFISAcava
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Post by IFISAcava on May 6, 2017 16:02:36 GMT
You can open more than one IFISA in a tax year but cant subcribe new money to more than one, you need to transfer exisiting ISA funds. I hope this is the case (I would like to open 3-4 IFISAs this tax year and transfer some money to each from a previous year cash ISA). However, I can't find a statement on HMRCs website saying you are allowed to open more than one ISA of a given type in a given tax year. Are you basing this on absence of a statement saying this is not allowed, or have you had it confirmed from an authoritative source that it is allowed? Thanks The definitive ISA rules are quite clear on this
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ozaz
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Post by ozaz on May 6, 2017 16:25:25 GMT
I hope this is the case (I would like to open 3-4 IFISAs this tax year and transfer some money to each from a previous year cash ISA). However, I can't find a statement on HMRCs website saying you are allowed to open more than one ISA of a given type in a given tax year. Are you basing this on absence of a statement saying this is not allowed, or have you had it confirmed from an authoritative source that it is allowed? Thanks The definitive ISA rules are quite clear on this (don't know if these are the definitive rules or just a user-friendly synopsis of full rules) is clear that you can only subscribe to one ISA of each type in a given tax year. It is also clear that you can transfer funds accumulated in previous years between ISAs without restriction. However, I don't see clarity on the issue of whether or not you can open multiple ISAs of the same type in the same tax year. Please do link me to the HMRC statement that makes this clear. Similar to rogerbu, I did this last year with S&S ISAs (before I thought of checking), but am now wondering if it is actually allowed. Good to hear that HL say it is allowed, but would prefer to see something clear from HMRC before I do the same with IFISAs. I have emailed HMRC but I don't expect I will get a response for several days.
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IFISAcava
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Post by IFISAcava on May 6, 2017 16:38:33 GMT
The definitive ISA rules are quite clear on this (don't know if these are the definitive rules or just a user-friendly synopsis of full rules) is clear that you can only subscribe to one ISA of each type in a given tax year. It is also clear that you can transfer funds accumulated in previous years between ISAs without restriction. However, I don't see clarity on the issue of whether or not you can open multiple ISAs of the same type in the same tax year. Please do link me to the HMRC statement that makes this clear. Similar to rogerbu, I did this last year with S&S ISAs (before I thought of checking), but am now wondering if it is actually allowed. Good to hear that HL say it is allowed, but would prefer to see something clear from HMRC before I do the same with IFISAs. I have emailed HMRC but I don't expect I will get a response for several days. On this link HMRC says "You can transfer your Individual Savings Account (ISA) from one provider to another at any time". That covers it. And if partial transfers are allowed (as they are for previous years) it's clearly possible to transfer to more than one provider per year. You just can't put new money more than one of the same ISA type.
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ozaz
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Post by ozaz on May 6, 2017 16:53:38 GMT
On this link HMRC says "You can transfer your Individual Savings Account (ISA) from one provider to another at any time". That covers it. And if partial transfers are allowed (as they are for previous years) it's clearly possible to transfer to more than one provider per year. You just can't put new money more than one of the same ISA type. I do think your interpretation of that is most likely correct. But I'm still not happy with the absence of a statement from HMRC saying you can open multiple new ISAs of a given type in a tax year as long as you only subscribe to one. Lots of providers say you can only open one ISA of a given type in a tax year (e.g. like the guide at the start of this thread). I don't know if they're just conflating opening and subscribing or they are actually being specific to the term opening and know something which is not mentioned on HMRCs public-facing website.
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littleoldlady
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Post by littleoldlady on May 6, 2017 18:00:45 GMT
ozaz Best of luck getting the authoritative answer that you want. You will find this question in many threads (some by me) and the non-authoritative answer from very knowledgable people is always the same. But if you do get a clear answer from HMRC please post it here.
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mikeh
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Post by mikeh on May 7, 2017 13:19:50 GMT
The problem here seems to be how does “subscribing to an ISA” relate to “opening an ISA account”. HMRC's Guidance Notes for ISA Managers make it clear that as far as HMRC are concerned an ISA does not exist until a subscription has been made. So applying to an ISA manager to open an ISA does not of itself create an ISA in HMRC's eyes. In the financial world subscription means committing new money.
Once an ISA has been created by committing money to it, it can be transferred to a new ISA manager at any time. To the HMRC this does not create a new ISA. No additional money is being subscribed. The ISA is just being managed by a different manager. This right to transfer applies to both current year and prior years money. The only difference is this year's money must be transferred in full.
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littleoldlady
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Post by littleoldlady on May 7, 2017 14:20:55 GMT
The problem here seems to be how does “subscribing to an ISA” relate to “opening an ISA account”. HMRC's Guidance Notes for ISA Managers make it clear that as far as HMRC are concerned an ISA does not exist until a subscription has been made. So applying to an ISA manager to open an ISA does not of itself create an ISA in HMRC's eyes. In the financial world subscription means committing new money. Once an ISA has been created by committing money to it, it can be transferred to a new ISA manager at any time. To the HMRC this does not create a new ISA. No additional money is being subscribed. The ISA is just being managed by a different manager. This right to transfer applies to both current year and prior years money. The only difference is this year's money must be transferred in full. Yes this is what I think also and is the answer generally given. The problem is that AFAIK every ISA Manager requires an account to be "opened" on its platform before it will accept a transfer in. This opening process is in my experience always the same as opening an ISA for subscription. So the manager cannot tell if you are "opening" a new ISA or just preparing for a transfer. Inevitably all the comments and instructions to the applicant are framed as if it is the former. Indeed in the early days of ISAs I sometimes found it impossible to open an account, which I proposed to use only for a transfer, without making a subscription and so tying myself into that provider. Hence the confusion.
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ozaz
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Post by ozaz on May 7, 2017 14:22:48 GMT
mikeh Thank you. This is the best evidence I have seen that there is indeed a distinction between opening and subscribing, and therefore there should not be a limit on the number of ISAs of a given type one can open in a given tax year. The guidance notes are 361 pages long! No wonder there is confusion about rules.
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