The term “ISA” usually refers to the Individual Savings Account available in the UK — a tax-efficient way to save or invest money. But similar types of accounts exist in many countries, often under different names and rules. They all aim to help individuals grow their savings without paying unnecessary tax. But the similarities usually end there. Contributions, withdrawal rules, tax treatments and investment options vary widely by country.
This overview looks at how ISA-type accounts work across several countries, so you can compare or understand how your local version fits into the bigger picture.
United Kingdom — ISA (Individual Savings Account)
The UK ISA is the most recognisable version. There are different types: Cash ISAs, Stocks & Shares ISAs, Lifetime ISAs and Innovative Finance ISAs. The annual allowance is £20,000 (as of 2025), and any gains, interest or dividends are tax-free.
Accounts must be held in the name of a UK resident, and while you can switch between providers, the allowance resets every tax year. There are no taxes on withdrawals, no need to declare it to HMRC, and money can be accessed at any time, depending on the account type.
Sweden — Investeringssparkonto (ISK)
Sweden’s ISA equivalent is the Investeringssparkonto, or ISK. It simplifies tax reporting and gives people an easy way to invest in stocks, funds or bonds with a low flat-rate tax based on account value, not gains. You don’t pay capital gains tax on individual trades.
It’s not entirely tax-free, but the simplicity and low rates make it a popular choice, especially for long-term investing. Funds in ISK can be withdrawn at any time with no extra tax.
ISKkonto.se — Sweden’s ISK overview
Germany — Freistellungsauftrag & VL-Sparen
Germany doesn’t offer a direct ISA-style account, but savers can benefit from a Freistellungsauftrag, which allows tax-free gains up to €1,000 per year per person (€2,000 for couples). This applies to savings and investments, and you must actively file this exemption with each financial institution.
There’s also VL-Sparen, a state-subsidised savings scheme connected to employment contracts, where employers contribute to long-term savings. However, it has specific eligibility and low flexibility.
BMF — German tax exemption info
France — Plan d’Épargne en Actions (PEA)
France’s PEA offers tax benefits for those investing in shares of EU-based companies. After five years, withdrawals are tax-free (though social contributions still apply). There’s a cap of €150,000, and the account must be opened with a French financial institution.
It’s not as flexible as other models, and the focus is more on long-term equity investment than simple saving.
Service-Public.fr — PEA account
United States — Roth IRA and 401(k)
In the US, tax-advantaged accounts are split between employer-sponsored (like 401(k) plans) and individual accounts like the Roth IRA or Traditional IRA. Roth IRAs are closest in spirit to an ISA: you contribute after-tax money, it grows tax-free, and qualified withdrawals are also tax-free.
Contribution limits are $7,000 per year (2025), and there are income caps for eligibility. Withdrawals are restricted by age and other rules.
Canada — Tax-Free Savings Account (TFSA)
Canada’s TFSA is widely regarded as one of the most flexible tax-free savings accounts globally. Any Canadian resident over 18 can contribute annually up to the limit (CAD $7,000 for 2024), and investment income, capital gains and withdrawals are all tax-free.
Unused contribution room rolls over, and you can withdraw funds at any time without penalty, making it extremely versatile for both short- and long-term goals.
Australia — Superannuation and Investment Bonds
Australia doesn’t have a direct ISA equivalent, but superannuation funds provide tax-deferred retirement savings. Contributions are taxed at a reduced rate, and investment growth inside the fund is taxed favourably.
For medium-term savings outside of retirement, investment bonds offer tax advantages if held for at least 10 years. After that, all proceeds are tax-free, similar to a long-term ISA.
Japan — NISA (Nippon Individual Savings Account)
Japan introduced NISA in 2014, heavily inspired by the UK’s ISA. The scheme allows individuals to invest a set annual amount in stocks or mutual funds tax-free for a limited period. A new version called Tsumitate NISA focuses on small, regular investments with a long-term view.
The system was updated in 2024, increasing limits and simplifying rules, aiming to boost household investment.
Norway — Aksjesparekonto (ASK)
Norway’s ASK is a share savings account that allows individuals to buy and sell shares and equity funds without triggering immediate taxation on gains. Taxes only apply when funds are withdrawn from the account, and only on the gains.
This system encourages long-term investment and gives individuals flexibility in managing portfolios without worrying about yearly tax filings.
