Additional Permitted Subscriptions (APS)
Anyone who was married or in a civil partnership with someone who died on or after 3 December 2014 can apply for an additional ISA allowance, known as the Additional Permitted Subscription (APS).
If the deceased died before 6 April 2018, the APS is equal to the value of the ISA on the date of death. For example, if your spouse died on or after 3 December 2014 (but before 6 April 2018) with an ISA valued at £75,000, this would be your APS.
If the deceased died on or after 6 April 2018, their ISA will be designated a 'continuing ISA'. It will keep this status until the earliest of:
- The completion of the administration of the estate
- The 3rd anniversary of the date of death
- The closure of the ISA due to all the funds being withdrawn
In this case, the APS is equal to the higher of the value of the ISA on the date of the investor's death or the value of the ISA on the date it stops being a 'continuing ISA'.
Where an investor held ISAs with several companies, a separate APS will be available for each.
The deceased and the surviving spouse must have been living together at the date of death. That is, not separated under a court order, under a deed of separation, or in circumstances where the marriage or civil partnership has broken down.
Additional permitted subscriptions:
- Can be made with the manager who held the deceased's ISA or another Manager who agrees to accept the subscriptions (although transfers to another manager MUST be made in cash and not stock)
- Can be made to a cash, or stocks and shares ISA (but if the surviving spouse is 16 or 17, only to an adult cash ISA)
- Can be made in cash or inherited non-cash ISA assets (with the same Manager only for non-cash assets)
- Are available whether or not the surviving spouse inherited the deceased's actual ISA assets
- Can be made by non-residents
- Cannot be made to or from a Junior ISA
What are the time limits to use the APS?
- An APS made as stock must be completed within 180 days of the distribution of the assets to the surviving spouse
- An APS made as cash is available for three years after the date of death, or for up to 180 days after the administration of the estate is complete, whichever is later.
The value of the deceased's ISA can be requested from the ISA Manager providing the request is made in writing and contains the following information about the deceased:
- Their name & address
- Their National Insurance number (if known)
- Their date of birth & date of death
- The date of marriage or civil partnership to the applicant
- A declaration that, the application is the surviving spouse and that the applicant and deceased were living together at the deceased's date of death.
Where the deceased had a number of ISAs with a Manager, there will be a single additional subscription based on the combined value of those ISAs at the investor's date of death.
Making additional permitted subscriptions
The surviving spouse can make an APS with either the Manager who held the deceased's ISA or another Manager who agrees to accept the subscriptions, although this would have to be made in cash only.
Once an APS has been made with one Manager, any further APS up to the limit must be made with the same Manager.
The subscription can be made to a Stocks & Shares ISA, which the surviving spouse holds with that Manager, or to a new ISA opened for specifically for this purpose.
Where a surviving spouse inherits non-cash ISA assets ie. stocks and shares, these may be used to make an APS 'in specie' ie. without having to be sold and the subscription made in cash, provided these assets were the ones held at the date the Manager was notified of the investor's death. The option of an 'in specie' subscription is not available if the spouse decides to make an APS to a Manager other than the one who held the ISA of the deceased.
Where the deceased held a combination of Stocks & Shares and cash ISAs with the same Manager, the surviving spouse will have a single APS limit with that Manager.
Where the assets change after the ISA Manager is notified of the death of the investor as a result of a corporate action, those 'new' assets will be eligible for in-specie transfer.
Does Jarvis allow Additional Permitted Subscriptions?
Yes - you will need to open an ISA account if you do not currently have one with Jarvis. Please click here to apply for an ISA.
What forms do I need to fill in?
If you have an ISA with Jarvis, and your spouse had an ISA with Jarvis and you wish to deposit the additional permitted subscription allowance with ourselves, you will need to complete an APS application form. Complete this form and return the original to Jarvis.
I wish to transfer my spouse's ISA from another manager to my ISA at Jarvis - what form do I need to complete?
As shares cannot be transferred from one ISA Manager to another, any investments with the existing manager will need to be sold and the ISA transferred as cash. Please complete the transfer form and return this to Jarvis.
I have an existing ISA with Jarvis and would like to add more funds using my Additional Permitted Allowance - what do I need to do?
To top up your ISA allowance using additional permitted subscriptions (ie. you are not transferring in an ISA but topping up against the value of the deceased's ISA), you simply need to complete a declaration form and return this to our office. Payments must be made by cheque or bank transfer to ensure that this is added to your ISA under the APS rule.