Expat Tax Rules
UK tax obligations for expats, non-domiciles and returning residents — the Statutory Residence Test, the new non-dom rules and double taxation treaties explained.
UK Tax Residency — The Statutory Residence Test
Whether you are liable for UK tax depends primarily on your residence status, determined by the Statutory Residence Test (SRT) introduced in April 2013. The SRT has three parts: 1. Automatic Overseas Tests: You are automatically non-UK resident if you spent fewer than 16 days in the UK in the tax year (or 46 days if not resident in any of the previous 3 years). 2. Automatic UK Tests: You are automatically UK resident if you spent 183 or more days in the UK, your only home was in the UK, or you carried out full-time work in the UK. 3. Sufficient Ties Test: If neither automatic test applies, your residence depends on how many of five "ties" to the UK you have (family, accommodation, work, 90-day, country ties) combined with your day count.
Leaving the UK — Tax Implications
When you leave the UK and become non-resident: • You stop paying UK income tax on overseas income (generally) • UK-source income (rental income, employment income from UK work) remains taxable in the UK • You must complete a Self Assessment return for the year of departure using split-year treatment if applicable • Capital gains on UK residential property remain taxable regardless of residency • Leaving partway through the year may allow split-year treatment, dividing the year into UK-resident and non-resident parts
Returning to the UK
When you return to the UK and become resident again: • You become liable for UK tax on your worldwide income from the date residence resumes • Assets you held while non-resident are "rebased" for CGT purposes in some cases • Overseas pensions and income brought into the UK may be taxable • The "Remittance Basis" previously available to returning non-domiciles has been significantly reformed from April 2025
Non-Domicile Rules (Post April 2025)
The non-domicile (non-dom) tax regime was significantly reformed from 6 April 2025. The previous "remittance basis" — where non-doms could choose to pay UK tax only on income brought into the UK — has been replaced by a new residence-based system: • New arrivals to the UK: No UK tax on foreign income and gains for the first four years of UK tax residency (if not UK resident in any of the previous 10 years) • After four years, worldwide income and gains are fully taxable in the UK • A Temporary Repatriation Facility (TRF) allows past foreign income and gains to be brought to the UK at a reduced rate (12% in 2025/26, 12% in 2026/27, 15% in 2027/28) Existing non-doms on the remittance basis must review their position carefully.
Double Taxation Agreements
The UK has double taxation agreements (DTAs) with over 130 countries. These treaties prevent you from paying tax twice on the same income. DTAs typically: • Determine which country has the primary taxing right over different types of income • Allow credit relief so tax paid in one country reduces the liability in the other • Cover income, gains, pensions, dividends, royalties, and more The treaty provisions override domestic law in most cases, and specialist advice is recommended when cross-border income is involved.
UK Tax for Non-Resident Landlords
Non-residents who let UK property must register with the Non-Resident Landlord (NRL) scheme: • Rental income is still subject to UK income tax • Letting agents must withhold 20% tax at source unless the landlord has an NRL approval number from HMRC • Non-resident landlords must file Self Assessment returns to report rental income • Mortgage interest deductions and expenses are still allowable under the same rules as UK residents • Capital gains on UK residential property must be reported within 60 days of completion, regardless of residency
Key SRT Day Thresholds
Auto non-resident
< 16 days in UK
Auto non-resident (new)
< 46 days (if not resident 3yr)
Auto UK resident
183+ days in UK
Sufficient ties test
16–182 days + ties
Moving To or From the UK?
Cross-border tax is complex. We advise on residency, non-dom rules, and treaty planning.
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