Tax-Advantaged Investment Accounts Across Europe: ISK, PEA, ASK, Pillar 3a, PIR and More

Published 3 November 2026 by Steffan Kharmaaiarvi, founder

Most European countries offer a tax-advantaged investment account, and no two work alike. Some tax the account's value every year, some tax its return, some tax only withdrawals. For an adviser reviewing a cross-border portfolio, the question that changes the numbers is often the quietest one: what happens to foreign dividend withholding inside the account? In some it is credited, in others it is simply lost.

At a glance

Sweden: investeringssparkonto (ISK)

Dividends and gains in an ISK are not taxed. Instead Skatteverket taxes a standard income (schablonintäkt): a capital base, the four quarterly opening values plus the year's deposits divided by four, times the government borrowing rate on 30 November of the previous year plus one percentage point, with a floor of 1.25%. For 2026 that rate is 2.55% + 1 = 3.55%, taxed at 30%: 1.065% of the capital base. From 2026 the first SEK 300,000, shared across ISK, kapitalförsäkring and PEPP savings, is tax-free. Foreign tax on foreign shares in the account can be credited, but not beyond the Swedish tax on the ISK; any excess carries forward to later years.

France: plan d'épargne en actions (PEA)

The PEA holds European company shares and funds that invest more than 75% in shares, with a deposit cap of EUR 150,000. Gains and dividends reinvested inside are exempt from income tax and social charges. A withdrawal before the end of the fifth year closes the plan, subject to listed exceptions; after five years gains are exempt from income tax but, whenever the withdrawal, subject to social charges (service-public gives 18.6% as the general 2026 rate on investment income, with special rules for some investments). BOFiP states that treaty tax credits on dividends from European companies outside France do not give rise to a refund inside a PEA, because the income is not taxed: foreign withholding is a final cost.

Norway: aksjesparekonto (ASK)

An ASK may hold listed shares and equity certificates of EEA companies and EEA equity funds with more than 80% in shares (skatteloven §10-21). Gains and dividends on them are exempt while in the account; withdrawals count first as a return of deposits, and only amounts beyond the deposits are taxable income. With no Norwegian tax on the dividends inside, there is nothing for foreign withholding to be credited against while they stay there.

Denmark: aktiesparekonto

The account is taxed at 17% of its yearly return, measured on the mark-to-market principle at year end, so unrealised gains count. The bank calculates and pays the tax. The 2026 deposit cap is DKK 174,200. Under Aktiesparekontoloven §18, foreign tax on income from that state can be deducted from the 17% tax, but not beyond 17% of that income and, where a treaty applies, not beyond what the source state may levy under it; an excess is carried forward as negative tax.

Finland: osakesäästötili

Up to EUR 100,000 can be deposited, and only listed shares can be bought: Vero's guidance excludes funds and ETFs. Dividends and gains are not taxed when they arise; on a withdrawal the earnings share is taxed as capital income, 30% up to EUR 30,000 and 34% above. Vero is explicit that foreign withholding on dividends in the account cannot be credited in any situation; only the net dividend counts as the account's return.

Switzerland: pillar 3a

Contributions are deductible: in 2026 up to CHF 7,258 with a pension fund, or 20% of earned income up to CHF 36,288 without one. Balances are exempt from wealth tax, and lump-sum withdrawals are taxed separately from other income, at one fifth of the federal tariff (Art. 38 DBG, ESTV Kreisschreiben Nr. 18a). Where securities are held in an individual depot, the bank foundation reclaims Swiss withholding tax; the account holder has no claim of their own. Art. 10(3) of the US–Swiss treaty exempts US dividends paid to Swiss retirement arrangements that the two competent authorities recognise, and a 2024 arrangement lists the plans covered. Most 3a money, however, sits in funds, where withholding is suffered inside the fund.

Italy: piano individuale di risparmio (PIR)

A PIR is for individuals tax-resident in Italy. At least 70% must go into qualifying investments in Italian-rooted companies, with concentration limits. Investment income and financial gains are exempt, as is the plan for inheritance tax, provided each investment is held for five years. The Agenzia delle Entrate's circular states that the exemption does not extend to taxes applied abroad on the same income, and that no credit for foreign taxes under art. 165 TUIR is due on it.

A worked example

Illustrative figures for 2026. A Swedish client has an ISK with a capital base of SEK 1,000,000 and receives SEK 20,000 of US dividends in it, with 15% (SEK 3,000) withheld.

• Standard income: 1,000,000 × 3.55% = 35,500. Tax-free level: 300,000 × 3.55% = 10,650. Taxable: 24,850 × 30% = SEK 7,455, which is 1.065% of the 700,000 above the tax-free level.
• Foreign tax credit: 3,000, below the 7,455 limit. ISK tax payable: SEK 4,455.
• The same SEK 3,000 withheld in a Finnish osakesäästötili, a PEA or a PIR would be lost for good; in a Norwegian ASK there is no tax inside to set it against.

That is why the same US holding can be the right one in an ISK and a poor one in an osakesäästötili, where the account's rules allow it at all.

What Borderfolio shows

Each of these accounts is a built-in wrapper preset, set per account and applied by the tax engine at the wrapper's rates; the presets also cover the assurance-vie, Riester, lijfrente, plan de pensiones, IKE, IKZE, PPR and PRSA, among others. Every value cites a primary source and the adviser can override it; a firm can also define its own presets. For the ISK the engine estimates the yearly account tax on today's value above the SEK 300,000 level, with foreign withholding credited. Foreign withholding is creditable in the ISK and aktiesparekonto presets and a final cost in the others; the pillar 3a preset assumes the US treaty exemption for US shares held directly by the foundation, without verifying how a provider obtains it.

Not modelled: tax on withdrawals (ASK, osakesäästötili, PEA, pillar 3a), the Danish tax on unrealised gains, the ISK's quarterly-average base (today's value is used), deposit caps and eligibility rules, and cantonal tax on 3a withdrawals. See the tax wrapper presets, the European withholding reclaim guide and the European edition.

Not tax advice. Rates and limits are summarised from the sources below as read on 3 November 2026 and change with each budget; confirm them for each client.

Sources: Skatteverket, investeringssparkonto, Skatteverket, belopp och procent 2026, Skatteverket, foreign tax in an ISK, Service-Public, PEA, Service-Public, social charges on investment income, BOFiP BOI-RPPM-RCM-40-50-30, Skatteloven §10-21, Aktiesparekontoloven, Skattestyrelsen, aktiesparekonto, Vero, equity savings account, Vero, osakesäästötilin verotus, BSV, the third pillar, ESTV Kreisschreiben Nr. 18a (pillar 3a), IRS, US–Switzerland competent authority arrangement on pension plans (2024), Agenzia delle Entrate, Circolare 3/E of 26 February 2018 (PIR).

Frequently asked questions

Is foreign withholding tax credited inside a Swedish ISK?

Yes. Skatteverket allows a credit for foreign tax on foreign shares in an ISK, up to the Swedish tax on the account; any excess can be carried forward to later years.

Can foreign withholding be credited in a Finnish osakesäästötili or a French PEA?

No. Vero states that foreign withholding on dividends in an osakesäästötili cannot be credited in any situation, and BOFiP states that treaty tax credits on European dividends received in a PEA do not give rise to a refund. In both, foreign withholding is a final cost.

How is the Danish aktiesparekonto taxed?

At 17% of the yearly return, measured on the account value at year end whether or not investments were sold. The bank calculates and pays the tax. Foreign tax can be deducted from it within the limits of Aktiesparekontoloven §18.