Split-Year Treatment: How UK Tax Works in the Year You Move

Split-year treatment is a relief that splits a single UK tax year into a UK part and an overseas part, so you are taxed as a UK resident only for the portion of the year that genuinely relates to your life in the UK. For the other part you are taxed broadly as a non-resident, which usually means your foreign income (GOV.UK) and many foreign gains arising then fall outside the UK charge.

The starting point is always the Statutory Residence Test (RDR3, GOV.UK). The SRT looks at the whole tax year and gives a single answer: resident or not resident. Split-year treatment does not change that answer. Instead, where you are resident for the year as a whole but have moved during it, the rules allow that resident year to be split so the overseas part is treated, for most income tax and capital gains tax purposes, as if you were not resident.

Split-year treatment applies automatically by operation of the rules once the conditions of a case are met, but in practice you still have to report it correctly. There is no separate election to make beyond completing your tax return properly. It is purely a UK domestic concept: it tells the UK how much of your worldwide income and gains to tax in the year of the move. The other country involved has its own residence rules, and a double tax treaty may also re-allocate taxing rights, which is why year-of-move planning is rarely a single-country exercise.

Split-year treatment applies only when you are UK resident for the tax year under the SRT and your circumstances fall within one of the eight statutory cases. If either limb fails, the year is not split.

Two common misunderstandings are worth clearing up at the outset:

• If the SRT makes you non-resident for the whole year, there is nothing to split. You are simply non-resident for 2026/27 and split-year treatment is irrelevant.
• If the SRT makes you resident for the whole year but none of the eight cases fits your facts, you are taxed as a UK resident on your worldwide income and gains for the entire year, even though you moved part way through it.
• Split-year treatment is only available to individuals, not companies or trusts.
• It generally does not override anti-avoidance rules, the temporary non-residence rules, or specific provisions for certain UK-source income.

There is also a prior-year condition baked into the cases. The leaver cases (1 to 3) require you to have been UK resident in the previous tax year, and the arriver cases (4 to 8) require you to have been non-resident in the previous tax year. This stops people splitting two years in a row over the same move.

Three cases cover people leaving the UK (GOV.UK) part way through a tax year: Case 1 (starting full-time work overseas), Case 2 (the partner of someone starting full-time work overseas), and Case 3 (ceasing to have any home in the UK). You must be UK resident for the year and have been resident the previous year for any of them to apply.

Five cases cover people arriving in the UK part way through a tax year: Case 4 (starting to have a home in the UK only), Case 5 (starting full-time work in the UK), Case 6 (ceasing full-time work overseas), Case 7 (the partner of someone ceasing full-time work overseas) and Case 8 (starting to have a home in the UK). You must be UK resident for the year and have been non-resident the previous year.

Where more than one case fits your facts, statutory priority rules decide which case applies and therefore the exact date the year is split. You do not get to pick the most favourable; the legislation sets the order.

For leavers, the cases are considered in numerical order. Case 1 is tested first, then Case 2, then Case 3. The first case whose conditions you fully meet is the one that applies, and it fixes your split date.

For arrivers the position is more nuanced. Broadly, where Cases 6 or 7 apply they take priority, and otherwise the case producing the earliest split date applies, so that the UK (resident) part of the year is as long as the rules require rather than as short as you might prefer. HMRC's guidance sets out the tie-breakers in detail, and because the split date drives the tax outcome, this is an area where a careful reading of your own dates against each case pays off. This is exactly the kind of analysis we run as part of a fixed-fee year-of-move review.

In the UK part of the year you are taxed as a UK resident on your worldwide income and gains; in the overseas part you are taxed broadly as a non-resident, so most foreign income and many foreign gains arising then fall outside the UK charge. That split is the whole point of the relief.

Some categories of income remain taxable in the UK regardless of which part of the year they arise in, because they have a UK source or are caught by specific rules:

• UK employment earnings for duties performed in the UK stay within UK tax in both parts of the year.
• Income from UK land and property, such as rent from a let UK home, remains UK-taxable throughout (subject to the Non-resident Landlord Scheme in the overseas part).
• UK pensions and certain other UK-source income generally stay taxable across the year.
• Foreign income and gains arising in the overseas part are usually outside UK tax, but watch the temporary non-residence rules: if you return to the UK after a period of non-residence of five years or fewer, certain gains and income realised while abroad can be pulled back into UK tax in the year of return.

For capital gains tax, the 2026/27 annual exempt amount is £3,000, and residential property gains are taxed at 18% within the basic-rate band and 24% above it. Timing a disposal so it falls in the overseas part of a split year can take a foreign gain outside the UK net entirely, but the same disposal of UK residential property is still reportable under the 60-day (GOV.UK guidance) UK Property Disposal return rules and may remain chargeable. The dividend rates for 2026/27 are 10.75% (ordinary) and 35.75% (upper), with a 39.35% additional rate and a continuing £500 dividend allowance, all of which apply to dividends arising in the UK part.

You claim split-year treatment by completing the residence supplementary pages, the SA109 (GOV.UK), as part of your Self Assessment tax return (GOV.UK) for the year of the move; it is not applied automatically just because you moved. You tell HMRC that you are resident for the year, that split-year treatment applies, and which case you are relying on.

In practice the steps are:

• Confirm your SRT position for 2026/27 first. You must be resident for the year before split-year treatment is in point.
• Complete the SA109, ticking that you consider split-year treatment applies and entering the relevant case number and the date the year is split.
• Report your worldwide income and gains for the UK part, and only your UK-source and otherwise chargeable items for the overseas part, on the main return and the relevant supplementary pages.
• Keep evidence of your travel dates, employment contracts, home arrangements and overseas tax residence, because the conditions are fact-heavy and HMRC can ask you to substantiate the case you have claimed.
• File online by 31 January after the tax year. For 2026/27 that deadline is 31 January 2028, with the paper filing deadline of 31 October 2027 if you do not file online. Note that HMRC's free online service does not support the SA109, so you will need commercial software or an agent.

Because the SA109 is the page most likely to be missed or mis-completed by people filing their own return after a move, this is one of the most common areas where we are asked to step in. We handle the full year-of-move return, SA109 and all, on a fixed fee agreed before we start.

These two hypothetical examples show how the relief works in practice using 2026/27 dates. The figures are illustrative only and chosen to make the mechanics clear, not to reflect any real client.

Leaver (Case 1). Imagine Priya is UK resident and signs a full-time contract in Singapore starting 1 September 2026. She meets the SRT's overseas full-time work conditions for the relevant period to 5 April 2027 and stays within the UK-day limits. Under Case 1 her 2026/27 year splits from 1 September 2026. Her UK salary from April to August 2026 is taxed as a resident; her Singapore salary from September 2026 onwards falls in the overseas part and is outside UK tax. If she sold an overseas investment in November 2026, the gain would normally sit in the overseas part and escape UK CGT, though she would need to keep the temporary non-residence rules in mind if she might return within five years.

Arriver (Case 5). Imagine Daniel was non-resident in 2025/26 and starts a full-time UK job on 1 October 2026, meeting the sufficient-hours test over the following 365 days. Under Case 5 his 2026/27 year splits from 1 October 2026. His overseas employment income from April to September 2026 falls in the overseas part and is outside UK tax; his UK earnings from 1 October onwards are taxed as a resident. If he also began renting a UK flat that he kept for the rest of the year, Case 8 might appear to apply too, but the priority rules would still fix the case and date that the statute directs rather than the one he would choose.