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Updated on 6 April 2024

Split year treatment on leaving the UK

If you are becoming non-resident under the statutory residence test, you should consider whether split year treatment applies in your last year of residence.

Introduction

There are three sets of circumstances in which split year treatment may apply to you in the year that you are last resident in the UK.

If you are non-resident in your year of departure (this can happen if you leave very early in the tax year), then you should consider split year treatment for the preceding year.

Broadly:

  1. If you leave in the UK to start full-time work overseas then you will generally split the year from the date you start that work.
  2. If this applies to your partner but not to you, then you can also split the year at the same time as them (or when you join them, if later).
  3. If neither of the above applies, then you can split the year when you stop having a home in the UK.

For more information on each of these possibilities, including the further conditions which apply, see below. It is very important that you work through the rules in detail as they may give an unexpected result.

If the UK part of the year overlaps with a period of residence overseas, then you may be dual resident for that period.

For more information on the impact of split year treatment generally, including more information how double tax agreements might in effect modify the date, see our main page on split year treatment.

First year of residence

Below we give an overview of the possibilities to split the year under the statutory residence test for the first year of residence. In each of the following cases, it is important to review the full conditions. See HMRC’s manual for further details.

Starting full-time work overseas

If you are leaving the UK and in the following tax year you are non-resident as a result of full-time work overseas, then in general you will split the year when your overseas work starts. This will usually apply when you are leaving the UK for a period of full-time overseas work which spans a complete UK tax year.

You will need to meet the conditions for full-time work overseas for the period between starting overseas work and the end of that tax year, with the relevant day limits apportioned accordingly.

You must be resident in the UK in the tax year preceding your year of departure (including where split year treatment applies).

For further information on the conditions, see HMRC’s manual.

Partner of someone starting full-time work overseas

If the above does not apply to you, but you are the partner of someone for whom it does, then you should also be able to split the year from the later of:

  • the day you join your partner to live together overseas, and
  • the day the overseas part of the year starts for your partner.

You must be resident in the UK in the tax year preceding your year of departure (including where split year treatment applies), and you must be non-resident in the UK in the following tax year.

There are further conditions which apply. For more information, see HMRC’s manual.

Ceasing to have a home in the UK

If neither of the above apply, you can split the year if you stop having a home in the UK for the rest of the tax year.

You may only spend a maximum of 15 days in the UK in the overseas part of the year, regardless of when you stopped having a home.

In addition, six months after ceasing to have a home in the UK, you must either:

  • be tax resident in another country (under that country’s laws), or
  • have been present in one foreign country for every day of that six-month period, or
  • your only home (or all homes) must be in one foreign country.

You must be resident in the UK in the preceding tax year (including where split year treatment applies), and you must be non-resident in the UK in the following tax year.

For more information on the conditions, see HMRC’s manual.

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