Moving to or leaving the UK: residence and tax
Whether you are UK resident decides whether the UK taxes your worldwide income and gains. Since April 2025 residence also decides whether your worldwide estate is within UK inheritance tax, so the planning matters in both directions.
By Andy Jackson, Head of Accountancy
Updated 26 October 2026
5 min read
Key takeaways
- UK residence for each tax year is decided by the statutory residence test, which counts days in the UK and your ties to it.
- Split-year treatment can divide the year of arrival or departure into a resident part and a non-resident part.
- Since 6 April 2025 domicile no longer decides how foreign income is taxed. New arrivals may claim four years of relief on foreign income and gains.
- Inheritance tax on worldwide assets now depends on long-term residence: broadly, being UK resident for 10 of the previous 20 tax years.
The statutory residence test
The test is applied separately to each tax year. It works through three stages in order:
- Automatic overseas tests. You are non-resident if, for example, you spend fewer than 16 days in the UK, or fewer than 46 days and were not resident in any of the previous three tax years, or you work full time abroad and meet the day and workday limits.
- Automatic UK tests. You are resident if you spend 183 days or more in the UK, or your only home is in the UK for a sufficient period, or you work full time in the UK.
- Sufficient ties test. If neither set of automatic tests settles it, the number of days you can spend in the UK without becoming resident depends on your ties: family, accommodation, work, days spent here in previous years and whether you spend more time here than in any other country.
A day generally counts if you are in the UK at midnight. There are exceptions for transit and exceptional circumstances, and extra days can be counted for people with several UK ties. Keep a travel diary and supporting records, because the burden of proof is on you.
The year you arrive or leave
Normally you are resident or non-resident for a whole tax year. Split-year treatment divides the year where you arrive or leave in one of the circumstances set out in the legislation, such as starting full-time work abroad or setting up your only home in the UK. Only the UK part of the year is then taxed as a resident. The cases are specific, so check which applies before choosing a moving date.
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Arriving in the UK
Since 6 April 2025 the remittance basis and the concept of domicile for income tax have been replaced. People who become UK resident after at least ten consecutive tax years of non-residence can claim relief from UK tax on foreign income and gains for their first four tax years of residence. The claim is made on the tax return each year, and foreign income must still be reported. Claiming it means losing the personal allowance and the capital gains tax annual exemption for that year.
Before arriving, review how your overseas investments, pensions and bank accounts will be taxed in the UK, and consider whether any assets should be sold, rebased or restructured first.
Leaving the UK
- UK income stays taxable. Rent from UK property and some UK pensions are still taxed in the UK after you leave. Non-residents are also taxed on gains on UK land and property.
- Temporary non-residence. If you return within five years, gains and some income received while abroad can be taxed in the year you come back.
- Tax treaties. Double taxation agreements decide which country has the first right to tax each type of income and how credit is given.
- Practical steps. Tell HMRC you are leaving, check your ISA position (you cannot add to an ISA once non-resident), and review your will in each country where you hold assets.
Inheritance tax and long-term residence
From 6 April 2025 a person is within UK inheritance tax on their worldwide assets if they have been UK resident for at least 10 of the previous 20 tax years. After leaving, that exposure continues for a period of between three and ten years depending on how long you were resident. Assets in the UK remain within inheritance tax whatever your residence. Transitional rules apply to people who were not UK-domiciled on 30 October 2024.
This changes the planning for families with homes or investments in more than one country. A will drafted in one country may not deal properly with assets in another, so wills and inheritance tax should be reviewed together.
The date you leave or arrive can change the tax on a bonus, a property sale or a pension payment by a large amount. Take advice several months before the move.
Frequently asked questions
How many days can I spend in the UK without becoming resident?
It depends on your ties to the UK and your residence history. Fewer than 16 days is always non-resident, and 183 days or more is always resident. Between those, the sufficient ties test decides.
Does non-dom status still exist?
No. From 6 April 2025 it was replaced by a residence-based system, including four years of relief on foreign income and gains for qualifying new arrivals.
Do I still pay UK tax after I emigrate?
On some income, yes. Rent from UK property, some pensions and gains on UK property remain taxable in the UK.
Does leaving the UK take my estate out of inheritance tax?
Not immediately. If you were a long-term resident, worldwide assets stay within inheritance tax for between three and ten years after you leave, and UK assets stay within it permanently.
Sources & further reading
This article is general information, not advice. Tax, financial and legal rules change and their effect depends on your circumstances. Check the current position and take professional advice before acting. Last reviewed 26 October 2026. Totus One Limited (company no. 16855798).
Founder of Buzz Accounting, Practice Group and Founder Capital, Andy has built businesses across accountancy, fintech, private equity and e-commerce. He brings the discipline of a COO, the mindset of a founder and the connections of an investor — and a conviction that most businesses aren't broken, they're just leaking time and money.
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