Specialist expat financial planner Blevins Franks is reporting that it is seeing a large increase in the number of UK IFAs enquiring about a move to Europe, spurred by passporting barriers post-Brexit.
The London-headquartered firm, which has offices in France, Spain, Portugal, Cyprus and Malta, is fully regulated in each country individually.
Jason Porter, Blevins Franks's director of specialist expat financial advisers, said: "UK IFAs may welcome the intellectual challenge of learning a new set of tax and estate planning rules in another country in order to serve their clients.
"Plus they get a new life in the sun, just like their clients!".
Qualified financial planners who used to be able to ‘passport' their services from Britain to the EU cannot now automatically do so post-Brexit.
"That is unless they have an operational base with local authorisation in an EU state, or join a company that has one," said Jason Porter, a director of specialist expat financial advisers Blevins Franks.
"So, they cannot offer advice to EU-based clients in situ."
On 30 December 2020, the UK and EU formally signed the Trade and Cooperation Agreement (TCA) - a legal contract that forms the basis of the ongoing relationship between the UK and the EU.
This agreement made little reference to financial services, he said.
Financial ‘passporting' in the EU meant that if an EU member state maintained its financial regulation, its local authorisation and its ongoing assessment of local financial businesses to EU rulebook standards, then firms from that member state could obtain and maintain approval to ‘passport' their financial products and services across other EU member states.
By 2016, there were 5,500 UK authorised firms passporting their services across Europe. As a result, most UK nationals would find their existing banks and investment managers in the UK could continue to advise them when they moved to the EU.
"Brexit and the Trade & Cooperation Agreement changed all that," said Porter.
The UK now has a ‘third country' status in terms of EU law. Without passporting or any special arrangements, the UK's financial rules would need to be deemed ‘equivalent' to those of the EU for the UK to gain access to these markets.