United Kingdom — Split Year Treatment (Arriving or Leaving Mid-Year)

Summary

What it does

Splits one tax year into a UK part and an overseas part

Qualifying routes

8 cases — 3 for leaving, 5 for arriving

Precondition

UK resident for the year under the SRT

Window

UK tax year, 6 April–5 April

How to claim

SA109 residence pages (case number + split date)

Authority

HMRC (RDR3 section 5, RDRM12000)

The UK Statutory Residence Test decides residency for a whole tax year — there is no such thing as being resident for part of a year under the test itself. Split year treatment is the fix: if you are UK resident for a year in which you genuinely arrive in or leave the UK, and you fit one of eight cases, the year is divided into a UK part (taxed as a resident on worldwide income) and an overseas part (taxed broadly as a non-resident). It is not a choice and not a concession — either a case applies or it does not — and it never turns a non-resident year into a resident one.

Who it applies to

Split year treatment is relevant if, in a single tax year, you:

• Moved abroad to start a full-time job (or went with a partner who did).
• Left the UK for good and gave up your UK home.
• Came to the UK to start full-time work, or to live here after a period abroad.
• Returned to the UK after a stint working full-time overseas.

It applies to individuals only, and only to years in which you are UK resident under the SRT. If the SRT says you were non-resident for the whole year, there is nothing to split.

The eight cases

Leaving the UK (Cases 1–3)

For all three you must have been UK resident in the previous tax year and be non-resident in the following tax year.

1. 1Case 1 — Starting full-time work overseas. You begin working sufficient hours overseas (35+ a week on average) and, from that date to 5 April, keep UK days and UK workdays within limits scaled from the normal 90 days / 30 workdays. The overseas part starts the day you begin overseas work.
2. 2Case 2 — Partner of someone in Case 1. You join a spouse, civil partner, or cohabiting partner who qualifies under Case 1 (or did in the previous year), and either have no UK home or spend more time in your overseas home. The split date is the later of your partner's date and your move.
3. 3Case 3 — Ceasing to have a home in the UK. You had a UK home at the start of the year, then had none; from that date you spend fewer than 16 days in the UK, and within six months you are tax resident elsewhere, or have your only home there, or are present there at midnight on every day. The overseas part starts the day you cease to have any UK home.

Arriving in the UK (Cases 4–8)

For all five you must have been non-resident in the previous tax year. The UK part starts on the split date and runs to 5 April.

1. 1Case 4 — Starting to have your only home in the UK. Until the split date you had no UK home (or did not meet the sufficient ties test up to that point); from it, your only home is in the UK and stays so to year-end.
2. 2Case 5 — Starting full-time work in the UK. You begin a 365-day period of sufficient UK work with no significant break, and did not have sufficient UK ties before the start date.
3. 3Case 6 — Ceasing full-time work overseas. You stop working sufficient hours overseas after having qualified as non-resident under the third automatic overseas test in the previous year, and were UK resident in at least one of the four years before that.
4. 4Case 7 — Partner of someone in Case 6. You move to the UK to join a partner who qualifies under Case 6 (this year or last), and were living with them overseas before the move.
5. 5Case 8 — Starting to have a home in the UK. You had no UK home at the start of the year, acquire one, keep it through the following tax year, and did not have sufficient UK ties before that date. Unlike Case 4, you may also keep an overseas home.

Priority order. If more than one case fits, RDR3 decides which one applies. Leaving: Case 1 beats Case 2, which beats Case 3. Arriving: Case 6 beats Case 5; Cases 4, 5 and 8 are ranked by whichever gives the earliest split date; Case 7 sits alongside them in HMRC’s table. The case chosen fixes the split date, and the split date fixes how much of the year is UK-taxed.

Why it exists: without it, someone who left the UK in May would owe UK tax on a full year of overseas salary, and someone arriving in February would be taxed on eleven months of foreign income earned before they set foot here. Split year treatment restricts worldwide taxation to the months you actually lived in the UK, while keeping strict, checkable conditions so the year cannot be split simply by taking a long holiday.

Day limits and the split date

1. 1Confirm you are UK resident for the year under the SRT — otherwise there is nothing to split.
2. 2Find which case fits and note its split date: the day overseas work starts (Case 1), the day you cease to have a UK home (Case 3), the day UK work or your UK home begins (Cases 4, 5, 8), and so on.
3. 3Check the case's day limits. Case 1: UK days and UK workdays in the overseas part must stay within the 90-day and 30-workday limits scaled pro rata to the months remaining. Case 3: fewer than 16 UK days in the overseas part. Arrival cases: you must not have had sufficient ties (under the normal SRT tables, scaled) before the split date.
4. 4Count days the SRT way — a day counts if you are in the UK at midnight; departure days before midnight generally do not count.
5. 5Report it on the SA109 residence pages: tick the split year box, give the case number and the date the UK part starts or ends.

The scaled limits are where most mistakes happen. If you leave under Case 1 on 6 October, the overseas part is six months, so the 90-day allowance for that part becomes roughly 45 days and the 30-workday limit roughly 15. The UK SRT calculator counts your UK midnights from trip dates so you can check the overseas part against the scaled figure.

Examples

• Job in Dubai from 1 September. Amira works full-time in the UK until August, starts a full-time Dubai role on 1 September, and spends 20 days in the UK before 5 April, none of them workdays. She is UK resident for the year (she was here 150+ days) but Case 1 applies: the UK part is 6 April–31 August, the overseas part 1 September–5 April, and her Dubai salary is outside UK tax provided she is non-resident the following year.
• Leaving without a job. Ben sells his London flat on 15 July, moves to Portugal, becomes Portuguese tax resident in November, and visits the UK for 10 days at Christmas. Case 3 applies — no UK home from 15 July, fewer than 16 UK days after it, resident elsewhere within six months. Had he kept the flat available to use, no case would fit and the whole year would stay UK resident.
• Arriving for work in January. Chloé, non-resident for years, starts a full-time London job on 12 January and has had no UK ties before then. Case 5 applies: the UK part runs 12 January–5 April, and her foreign salary for April–January is not UK taxable even though she is UK resident for the year.

Exceptions & edge cases

• Non-resident years cannot be split. If the SRT makes you non-resident for the whole year, you are simply non-resident — split year treatment only ever reduces a resident year.
• The following year matters. The leaving cases require non-residence in the next tax year. If you come back early and become resident again, the split is undone and the departure year is taxed in full.
• Temporary non-residence. If you are away for five years or fewer, certain income and gains realised while abroad — dividends from close companies, pension lump sums, gains on assets held before you left — are taxed in the year you return, split year or not.
• UK-source income in the overseas part stays taxable, subject to the non-resident rules and any treaty relief. Rent from UK property is the common example.
• Treaties. If you are also resident in the other country for the overlapping period, its treaty with the UK may allocate income differently from the domestic split; the treaty position takes precedence where you claim it.

Common misconceptions

• “I left in June, so I was only resident until June.” Only if a case applies. Leaving with no full-time job abroad and a UK home still available means no split — the whole year is resident.
• “I can choose whether to split the year.” No. If a case applies, the year is split; if none does, it is not. What you choose is only whether to report it correctly.
• “Split year means the 90-day limit still applies to me.” The limits in the overseas part are scaled down in proportion to its length — a six-month overseas part gets roughly half.
• “It is the same as being non-resident.” You remain UK resident for the year for most purposes; the overseas part only changes how income arising in that part is taxed.

Frequently asked questions

Sources

• HMRC — RDR3: Statutory Residence Test, section 5 (Split years)
• HMRC — Residence, Domicile and Remittance Basis Manual, RDRM12000: Split year treatment
• GOV.UK — Residence, remittance basis etc. (SA109) notes