Services

International tax & UK residence.

International tax advisors for internationally mobile individuals and overseas clients with UK exposure. Since 6 April 2025, UK tax on foreign income, gains and estates turns on residence, not domicile, so your residency position comes first.

Residence comes first.

Almost everything else follows from whether you are UK resident for the tax year.

If you are UK resident, by default you are resident for the whole tax year. In the year you arrive or leave, split year treatment can divide the year into a UK part and an overseas part, if you meet one of the qualifying cases. Foreign income and gains from the overseas part are then generally outside UK tax.

We work through the Statutory Residence Test and the split year cases with you, then look at how your overseas income, gains and assets are taxed and where double taxation relief applies. The aim is a UK position that is correct, planned in advance and able to hold up if HMRC asks questions.

Our international tax services.

Residence, overseas income and UK property for people with lives in more than one country.

01

Statutory Residence Test & split year

Your UK residence worked out year by year under each stage of the test, with split year treatment in the year you arrive or leave and the evidence kept to support it.

  • Automatic tests
  • UK ties
  • Day counts
  • Split year
Moving to or from the UK
02

Arriving & the FIG regime

Whether you qualify for four years of relief on foreign income and gains after ten years abroad, which sources to claim for, and whether claiming is worth losing your allowances.

  • Four-year FIG regime
  • Claim modelling
  • Arrival planning
Moving to the UK
03

Overseas Workday Relief

Relief for qualifying new residents on earnings for work done outside the UK, within the annual limit of the lower of 30% of the employment income or £300,000.

  • Overseas workdays
  • Employment income
  • Annual limit
Share schemes
04

Leaving the UK

Breaking UK residence cleanly: which UK ties still count, how many days you can spend here, what stays taxable, and the five-year temporary non-residence rules.

  • Breaking residence
  • Day counts
  • Temporary non-residence
Leaving the UK
05

Overseas income & gains

Reporting foreign employment, investments, pensions and property, and advice before bringing older overseas income into the UK, including the Temporary Repatriation Facility.

  • Foreign income
  • Overseas gains
  • Temporary Repatriation Facility
Residence, not domicile
06

Double taxation relief

Where the UK and another country both tax the same income or gains, we claim relief under the treaty or as a credit, and work through how the two tax years interact.

  • Tax treaties
  • Foreign tax credits
  • Relief claims
Personal tax
07

Non-resident landlords

The Non-Resident Landlord Scheme, approval to receive rent without deduction, and the UK tax return you still need to file on your UK rental profits.

  • NRL scheme
  • Gross rent approval
  • UK returns
Non-resident landlords
08

UK property sales by non-residents

Reporting a sale of UK property or land within 60 days of completion, even where no tax is due, and working out any capital gains tax.

  • 60-day reporting
  • Capital gains tax
  • UK land
Selling a buy-to-let
09

Inheritance tax

Inheritance tax now follows long-term UK residence rather than domicile. We look at how long your UK exposure lasts and plan cross-border estates, including the transitional rules for trusts.

  • Long-term residence
  • Cross-border estates
  • Trusts
Inheritance tax planning

Already abroad, or about to move? Talk to us before the move: the dates you choose can change the result.

Residence and international figures.

183 daysIn the UK in a tax year makes you automatically UK resident
16 or 46 daysFewer than 16 days (if UK resident in any of the previous 3 years) or 46 days (if not) makes you automatically non-resident
4 yearsOf relief on foreign income and gains for new residents after 10 consecutive tax years of non-residence
£300,000Annual cap on Overseas Workday Relief, or 30% of the employment income if lower
12%Temporary Repatriation Facility rate for pre-6 April 2025 foreign income and gains in 2025/26 and 2026/27, rising to 15% in 2027/28
10 of 20Tax years of UK residence that make you a long-term UK resident for inheritance tax
60 daysTo report a sale of UK property or land by a non-resident, even if no tax is due
5 yearsReturn to the UK within this period and some income and gains from your time abroad can be taxed on your return

Sources: GOV.UK guidance on the Statutory Residence Test (RDR3), the 4-year foreign income and gains regime and Overseas Workday Relief; AP Tax Advisors 2026/27 tax rates card.

The Statutory Residence Test, explained.

Your residence is decided for each tax year by the Statutory Residence Test. The tests are taken in order, and the first one that settles your position decides it. A day usually counts as a UK day if you are in the UK at midnight, with some exceptions.

Automatic overseas tests

If you meet any of these, you are automatically non-UK resident for the tax year:

  • you spend fewer than 16 days in the UK, and you were UK resident in one or more of the previous three tax years
  • you spend fewer than 46 days in the UK, and you were not UK resident in any of the previous three tax years
  • you work full-time overseas for the tax year, spend fewer than 91 days in the UK, work more than 3 hours in the UK on fewer than 31 days, and have no significant break from overseas work

Automatic UK tests

If none of the overseas tests applies and you meet any of these, you are automatically UK resident:

  • you spend 183 days or more in the UK in the tax year
  • you have a home in the UK for at least 91 consecutive days, at least 30 of them in the tax year, you are present in it on at least 30 days, and you have no overseas home or spend fewer than 30 days in any you have
  • you work full-time in the UK for any 365-day period that falls at least partly in the tax year, with more than 75% of the days on which you work more than 3 hours being days worked in the UK

Sufficient ties test

If no automatic test settles it, your UK ties are combined with your UK days. The ties are:

  • family: a spouse, civil partner or partner, or a child under 18, who is UK resident
  • accommodation: a place to live in the UK that is available to you for at least 91 consecutive days and where you spend at least one night in the year
  • work: working more than 3 hours a day in the UK on at least 40 days
  • 90-day: more than 90 days in the UK in either of the previous two tax years
  • country: for people who were UK resident in any of the previous three years, being in the UK more than in any other single country

The more ties you have, the fewer days you can spend here. You are UK resident if you have at least this many ties:

Days in the UKUK resident in any of the previous three yearsNot UK resident in any of them
16 to 454 tiesAlways non-resident
46 to 903 ties4 ties
91 to 1202 ties3 ties
121 to 1821 tie2 ties

The country tie only counts for people who were UK resident in any of the previous three years.

Split year treatment.

If you are UK resident for a tax year, you are resident for the whole of it unless split year treatment applies. It applies only if your circumstances fit one of eight cases:

  • Leaving the UK: starting full-time work overseas, being the partner of someone who does, or ceasing to have any home in the UK
  • Arriving in the UK: starting to have your only home here, starting full-time work here, ceasing full-time work overseas, being the partner of someone ceasing full-time work overseas, or starting to have a home here

Each case has its own conditions, and where more than one applies, priority rules decide the split date. The overseas part of the year is then treated broadly as a period of non-residence.

The foreign income and gains regime.

From 6 April 2025, all UK residents are taxed on their worldwide income and gains as they arise, and domicile no longer decides how foreign income and gains are taxed. The remittance basis was abolished and replaced by the four-year foreign income and gains (FIG) regime for new arrivals.

How it works:

  • Who qualifies: people in their first four tax years of UK residence, after at least ten consecutive tax years of non-UK residence. Nationality and domicile are irrelevant.
  • What is covered: most foreign income and gains, such as profits of an overseas trade or property business, dividends from non-UK companies, foreign interest and foreign capital gains.
  • What is not: foreign employment income, although Overseas Workday Relief may give relief for work done abroad.
  • No UK tax on relieved income and gains, and they can be brought into the UK without a tax charge.
  • You choose which sources to claim for, on your Self Assessment return, year by year. Unused years cannot be carried forward.

Claiming has a cost: you lose the personal allowance and the capital gains tax annual exempt amount for that year, and the foreign income still counts towards adjusted net income for the High Income Child Benefit Charge and childcare support. That is why we model it before you claim.

If you used the remittance basis before April 2025, the Temporary Repatriation Facility lets you designate earlier foreign income and gains and pay a flat charge of 12% in 2025/26 and 2026/27, or 15% in 2027/28.

Read: Residence, not domicile: how the UK taxes overseas income now →

Double taxation relief.

Where the UK and another country both tax the same income or gains, double taxation relief usually prevents you paying twice, either through the terms of a double tax treaty or by crediting the foreign tax against the UK tax. Relief has to be claimed correctly, and the interaction between two countries' rules and tax years needs care.

Non-resident landlords & UK property.

If you live abroad and let UK property:

  • your letting agent, or your tenant if the rent is over £100 a week, must deduct basic rate tax from the rent under the Non-Resident Landlord Scheme
  • HMRC can approve you to receive the rent without deduction
  • you still file a UK tax return on your rental profits
  • if you sell UK property or land, the sale must be reported to HMRC within 60 days, even where no tax is due

Read: Non-resident landlords and UK property →

Leaving the UK: tax.

Leaving cleanly means understanding which UK ties still count, how many days you can spend here, what happens to UK income and property you keep, and how long inheritance tax exposure continues under the long-term residence rules. If you return within five years, some income and gains from your time abroad can be taxed on your return.

Planning pointThe tax year in which you arrive or leave matters. Talk to us before the move.

Moving to or from the UK: how we help →

How our engagement works.

First conversation

A confidential call about your move or your overseas interests: dates, family, work, homes and assets in each country. We tell you which questions need answering first and what the work would involve.

Scope and fixed fee

We confirm in writing what we will review and the fixed fee. Work starts once the engagement letter is signed and our identity and anti-money laundering checks are complete.

Residence review and advice

We work through the Statutory Residence Test, split year cases and the FIG regime with your facts, then set out in writing your position, the options and the dates that matter.

Returns and ongoing support

We prepare your UK returns and claims, deal with HMRC for you, and review your position each year while your circumstances span more than one country.

International Tax, answered.

All questions →

Residence

Residence is decided each tax year by the Statutory Residence Test: first the automatic overseas tests, then the automatic UK tests, then the sufficient ties test, which combines your UK ties with the days you spend here. We work through it with you year by year.

It depends on your ties. Fewer than 16 days is always safe, and fewer than 46 days is safe if you were not UK resident in any of the previous three years. Above that, the number of UK ties you have decides it, and 183 days or more makes you resident whatever your ties.

Normally, if you are UK resident you are resident for the whole tax year. Split year treatment divides the year you arrive or leave into a UK part and an overseas part, but only if you fit one of eight specific cases, such as starting full-time work abroad or starting to have your only home in the UK.

For income tax and capital gains tax, mostly no: since 6 April 2025 the UK uses residence. But if you used the remittance basis before then, old overseas income and gains are still taxed when brought to the UK, so take advice before moving that money. For inheritance tax, long-term residence has replaced domicile for most purposes, although transitional rules still matter for some people and trusts.

Moving to the UK

Speak to us before you arrive. Your first UK tax year, whether split year treatment applies, and whether the four-year foreign income and gains relief is available all depend on dates and facts that are easiest to plan in advance.

The four-year foreign income and gains regime lets people who become UK resident after at least ten consecutive tax years abroad claim relief on most foreign income and gains for their first four years of residence. Claiming means losing the personal allowance and the capital gains annual exempt amount for that year.

If you are UK resident, yes, on your worldwide income and gains as they arise, unless you qualify for and claim the FIG regime or Overseas Workday Relief. Tax paid abroad can usually be credited against the UK tax.

Usually not. Double tax treaties and foreign tax credit relief generally prevent it, but relief has to be claimed correctly.

Leaving the UK and non-residents

Yes. If you file Self Assessment returns, you tell HMRC through your return. If you do not, you normally use form P85. It is also worth checking what UK income you will still have and whether you need to keep filing.

Often, yes. For example, if you have UK rental income, UK employment income, or have sold UK property. Non-residents must also report any disposal of UK property or land within 60 days.

It requires your letting agent, or your tenant if the rent is over £100 a week and there is no agent, to deduct basic rate tax from rent paid to a landlord whose usual place of abode is outside the UK. HMRC can approve you to receive the rent without deduction, and you still file a UK tax return.

Under the temporary non-residence rules, some income and gains you realise while abroad, such as gains on assets you owned before leaving and certain company distributions, can be taxed in the year you return.

Related pages.

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