 Otherwise all past year money would have to be replaced before any current year money would count as being replaced, due to the rules that current year money is the first withdrawn and last replaced.Past year money does have to be replaced before being transferred in the usual ISA transfer way, it must not be directly placed into the new account or it would count as a new current year subscription instead of a replacement.Interest on cash held in an ISA, including stocks and shares ISAs, is not subject to income tax.