As far as I know S32 dividends, because of arrangements it has made with UK authorities, are treated like any other UK dividend in that no overseas tax is deducted. Same as BLT for example. So there are no particular tax issues indicating that this share is especially better off in an ISA but as a generality I advocate that HYPers use ISAs to the max anyway.
TUI is entirely different in that German withholding tax is applied to the dividend. Holding in an ISA makes no difference to that fact and the tax is not recoverable. However if held direct outside an ISA, foreign dividends like this are taxed differently from UK payouts in that credit is given for the German tax deducted up to the investor’s marginal income tax rate. Such foreign dividends are not part of the annual tax free dividend allowance.
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