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

Split-year treatment is a rule under the Statutory Residence Test that splits a single UK tax year into a UK part and an overseas part when you move to or from the UK partway through the year. During the UK part you are taxed broadly as a UK resident, and during the overseas part you are taxed broadly as a non-resident, even though your formal residence status for the year as a whole is still 'resident'.

The reason it matters is that the UK tax year runs from 6 April to 5 April and, under the SRT, you are normally either resident or non-resident for that entire year. There is no concept of being a UK resident for half a year. So if you move abroad in, say, July, the default position would treat you as UK resident for the whole 2025/26 year and potentially tax your worldwide income and gains right up to 5 April 2026, including everything you earned after you left. Split-year treatment fixes that mismatch by carving the year in two at the date you genuinely moved.

It is important to understand what split-year treatment does not do. It does not change your residence status: you remain UK resident for the year as a matter of law. It simply changes the basis on which income and gains arising in that year are taxed, relieving the overseas part from UK tax on most non-UK source income. It is also a purely UK concept. Other countries do not have to recognise it, so you still need to consider the tax rules of the country you are moving to or from, and any double tax treaty between the two.

Split-year treatment applies only when you are UK resident for the whole tax year under the Statutory Residence Test and your circumstances meet all the conditions of one of the eight defined cases. If you are non-resident for the year, split-year treatment cannot apply, because there is no UK-resident period to carve out in the first place.

This is the single most common misunderstanding. People who move abroad sometimes assume they need split-year treatment, when in fact they are non-resident for the whole year under the SRT and therefore do not need it at all. Equally, someone who is non-resident for the year they leave cannot use it. So the first step is always to run the Statutory Residence Test for the year in question and confirm you are resident. Only then do you ask whether a split-year case applies. Our free SRT calculator can help you work out your residence position before you go any further.

• You must be UK resident for the tax year under the SRT.
• Your facts must satisfy every condition of at least one of the eight cases.
• It applies automatically when those tests are met. It is not optional and not something you elect for or against.
• It is reported, not claimed in the negotiable sense: you tick the relevant boxes on the SA109 residence pages and enter the split date.
• If you are non-resident for the year, or you do not fit any case, the year is not split.

For people leaving the UK there are three split-year cases, numbered 1, 2 and 3, and you only need to meet one of them. Case 1 covers leaving to start full-time work overseas, Case 2 covers accompanying or joining a partner who is starting full-time work overseas, and Case 3 covers ceasing to have any home in the UK. In every leaver case you must have been UK resident in the previous tax year and you must be non-resident in the following tax year, which confirms that you have genuinely left.

For people arriving in the UK there are five split-year cases, numbered 4 to 8, and again you only need to meet one. They cover, in turn: starting to have your only home in the UK (Case 4), coming to the UK to start full-time work (Case 5), returning to the UK after a period of full-time work overseas (Case 6), accompanying a partner who is returning from full-time work overseas (Case 7), and starting to have a home in the UK (Case 8). In each arriver case you must have been non-resident in the previous tax year.

When more than one case fits your facts, priority rules decide which case applies and, crucially, which date the year splits on, because different cases can produce different split dates. The rules differ for leavers and arrivers.

For leavers, the order is fixed and simple: Case 1 takes priority over Cases 2 and 3, and Case 2 takes priority over Case 3. So if you qualify under both Case 1 and Case 3, Case 1 wins and its split date applies.

For arrivers the logic is different and is driven by which case gives the shortest overseas part of the year (that is, the earliest UK start date). Broadly, where Case 6 and Case 5 both apply, the one with the earlier split date applies, and otherwise Case 6; where Case 7 (but not Case 6) and Case 5 both apply, the one with the earlier split date applies, and otherwise Case 7; and where two or more of Cases 4, 5 and 8 apply, the case giving the earliest split date applies. The practical effect is that the rules tend to favour treating you as a UK resident from the earliest qualifying date.

• Leavers: Case 1 beats Case 2 beats Case 3 (fixed order).
• Arrivers: the case giving the earliest UK start date (shortest overseas part) generally wins, with specific tie-breakers between Cases 5, 6, 7 and between Cases 4, 5 and 8.
• Getting the priority and the split date right is essential, because the date determines exactly how much of your income and gains falls into the UK net.

In broad terms, income and gains arising during the UK part of the year are taxed as if you were UK resident, while most foreign income and gains arising during the overseas part are outside the UK net, as though you were non-resident for that part. UK source income, such as rent from a UK property or earnings from UK duties, generally remains taxable in both parts because the UK taxes UK source income regardless of residence.

There are important detailed rules that can pull specific items into charge even in the overseas part, designed to stop people sheltering income artificially. For example, certain employment income, pension lump sums, chargeable event gains, and gains on assets sold during a temporary period of non-residence can be treated as arising in the UK part or can be caught by anti-avoidance rules when you return. The timing of when income or a gain 'arises' is therefore critical, and crystallising a large bonus, dividend or capital gain on the right side of the split date can make a substantial difference.

The wider context for 2025/26 also matters. From 6 April 2025 the remittance basis was abolished and replaced by the Foreign Income and Gains (FIG) regime, under which qualifying new residents (broadly, those arriving after at least 10 consecutive non-resident years) can claim relief on foreign income and gains in their first four years of UK residence. Split-year treatment and the FIG regime are separate but can interact for people arriving in the UK, so an arriver should consider both. This is exactly the sort of cross-border timing question a fixed-fee planning review can map out before you move.

You report split-year treatment on the SA109 residence pages of your Self Assessment tax return, by ticking the split-year box and entering the date the UK part of the year begins or ends. For 2025/26 these pages are titled 'Residence and foreign income and gains (FIG) regime etc' (they were previously called 'Residence, remittance basis etc', and HMRC renamed them to reflect the new FIG regime). There is no separate election to make: split-year treatment applies automatically when you qualify, but you still have to flag it correctly on the return so HMRC taxes the right portion of your income.

On the 2025/26 SA109 you mark the box that confirms split-year treatment applies (note that you do not tick this if you have already indicated you were non-resident for the whole year, because the two are mutually exclusive). If more than one case applies, you mark the box that says multiple cases apply, and you enter the relevant split date in the dates box. The SA109 notes ask which case applies, so you need to have worked out the correct case and date, applying the priority rules, before you file.

• The SA109 residence pages cannot be filed through HMRC's own free online service.
• Paper SA109 returns for 2025/26 must reach HMRC by 31 October 2026.
• To file online you must use HMRC-recognised commercial software, which extends the deadline to 31 January 2027.
• Keep your travel records, employment contracts, and evidence of homes and ties, because HMRC can ask you to prove the case and the split date.
• If you get the case or the date wrong, you can over- or under-pay tax, so many movers have the residence pages prepared professionally.

The two hypothetical examples below show how the split works in practice. They are illustrative only and use made-up facts; your own position depends on your specific circumstances.

Leaver example: For example, suppose Priya has been UK resident for years and on 1 August 2025 she relocates to Dubai to start a full-time job, with no significant breaks, keeping her UK workdays and UK visits within the permitted limits and remaining non-resident for 2026/27. She is UK resident for 2025/26 overall, but Case 1 applies and the year splits on 1 August 2025. Her salary and other income for 6 April to 31 July 2025 is taxed as UK resident, while her Dubai earnings from 1 August 2025 to 5 April 2026 fall in the overseas part and are outside the UK net, although any UK rental income she keeps would still be taxable throughout.

Arriver example: For example, suppose Daniel has lived abroad for many years, was non-resident for 2024/25, and moves to London on 1 October 2025 to start a permanent full-time UK job, staying resident in 2026/27. Case 5 applies and the year splits on 1 October 2025. His foreign income and gains arising from 6 April to 30 September 2025 are generally outside the UK net (the overseas part), while everything arising from 1 October 2025 onwards is taxed as UK resident. If Daniel is also a qualifying new resident, he might separately claim FIG relief on foreign income and gains in the UK part of the year, which is a good reason to plan the move and the claim together.