Split Year Treatment Under the UK Statutory Residence Test
When an individual moves to or from the United Kingdom during a tax year, they face an immediate question: are they taxed as a UK resident for the full year, or only for part of it?
The answer lies in split year treatment, a mechanism within the Statutory Residence Test (SRT) that can divide a tax year into a UK part and an overseas part. During the UK part, the individual is treated as UK resident and subject to UK tax in the ordinary way. During the overseas part, they are treated broadly as non-resident — protecting foreign-source income and gains from UK tax.
Understanding whether split year treatment is available — and which of the eight prescribed cases applies — is essential for anyone arriving in or departing from the UK mid-year.
What Split Year Treatment Does
Without split year treatment, the SRT operates on a whole-year basis. If you are UK resident for a tax year (6 April to 5 April), you are UK resident for the entire year — even if you arrived on 4 April or departed on 7 April.
Split year treatment carves out an overseas part from the tax year, beginning either at the start of the year (if you left the UK during the year) or ending at the end of the year (if you arrived). Income and gains arising in the overseas part are generally outside the scope of UK income tax and capital gains tax, subject to important exceptions.
Split year treatment is not automatic. You must claim it on your Self Assessment return and satisfy the conditions of one of the eight cases set out in Schedule 45 of the Finance Act 2013.
The Eight Cases
The eight cases are divided into those for individuals leaving the UK and those arriving in the UK.
Cases for Departing Individuals
Case 1: Starting full-time work overseas
This case applies where:
- You are UK resident in the tax year
- You start a period of full-time work overseas during the year
- You have no significant UK work in the remainder of the year (no more than 30 days of UK work)
- You spend fewer than 91 days in the UK in the overseas part
- The period of full-time overseas work continues for the remainder of the tax year and beyond
If the conditions are met, the overseas part begins on the date you commence full-time overseas work. For most expatriate employees this is the most commonly applicable departure case.
Case 2: Accompanying a partner who starts full-time overseas work
Where you accompany (or join) a partner who satisfies Case 1, you may claim split year treatment yourself. You must not be in full-time UK employment or self-employment during the overseas part, and you must spend fewer than 91 days in the UK in that overseas part. The couple must be living together.
Case 3: Ceasing to have a home in the UK
If you cease to have a home in the UK during the tax year and, within six months, you have no UK home (and you are not resident in the UK the following year), you may claim split year under Case 3. This case is particularly relevant for those who do not have employment overseas but retire or relocate abroad.
The case requires that either:
- You have no UK home at all after the leaving date, or
- You have a UK home but spend fewer than 16 days in the UK in the overseas part
Case 3 is the departure case most likely to apply to retirees moving abroad and to individuals who do not work.
Cases for Arriving Individuals
Case 4: Starting to have a home in the UK only
Where you did not have a UK home before the split date and acquire one during the year, and you had no UK home for the entire overseas part of the year, Case 4 applies. This is a relatively narrow case — you must not have maintained a UK home at any point during the overseas part.
Case 5: Starting full-time work in the UK
Where you start a period of full-time UK work during the year, having not been full-time UK employed at the start of the year, and you were not UK resident in the prior year, Case 5 applies. The overseas part covers the period before the date you started full-time UK work.
Case 6: Ceasing full-time work overseas
This case applies to a returning individual who was non-resident in the previous tax year because they met the full-time work overseas (third automatic overseas) test, who had been UK resident in one or more of the four tax years before that, and who is UK resident in the following year. The overseas part covers the period up to the date full-time overseas work ceases.
Case 7: The partner of someone ceasing full-time work overseas
This is the arrival mirror of Case 2: where your partner satisfies Case 6 and you move to the UK to continue living together with them, you may claim split year treatment yourself. You must have been non-resident in the previous tax year and UK resident in the year of the move.
Case 8: Starting to have a home in the UK
Where you become UK resident in the year, you were non-resident in the prior tax year, and you acquire a UK home during the year (having had no UK home at the start of the year), Case 8 may apply. This is broadly the "new to the UK" case for individuals arriving without an employment trigger.
Priority Between Cases
Where more than one case might apply, specific priority rules determine which case governs. As a general principle:
- Departure cases take priority over arrival cases
- Among departure cases, Case 1 takes priority over Cases 2 and 3
- Among arrival cases, Cases 4 and 5 take priority over Cases 6, 7, and 8
In some years — particularly for individuals who depart and then return — it is possible that no case applies even though the individual is technically a full-year UK resident. This can produce unexpected full-year tax exposure.
The Overseas Part: What Is and Is Not Protected
During the overseas part of a split year, the following income and gains are outside UK tax:
- Foreign income (employment income, investment income, rental income from overseas properties)
- Foreign capital gains (gains on non-UK assets)
- Overseas pension income (subject to the relevant double tax treaty)
However, the following remain within UK tax scope even during the overseas part:
- UK-source income (UK employment income, UK rental income, UK bank interest)
- UK capital gains (gains on UK-situs assets including UK residential property)
- Income from UK pension schemes
This distinction is particularly important for individuals who retain UK investment portfolios or UK rental properties after moving overseas. The split year does not provide a clean break from UK tax — it only protects foreign-source income and gains from the date the overseas part begins.
Remittance Basis and Split Year
For individuals who were claiming the remittance basis before their departure, split year treatment interacts with the remittance basis rules in complex ways. Under the FIG (Foreign Income and Gains) regime introduced from April 2025, the position has changed for newly UK-resident individuals: there is a four-year FIG window for qualifying new arrivals. Split year treatment remains relevant for determining when UK residence begins in the arrival year, and therefore when the FIG clock starts.
For departing remittance basis users, the rules on what constitutes a remittance in the overseas part of a split year, and whether remittance basis is available at all in a split year, require careful analysis.
Practical Considerations for Arriving Individuals
An individual arriving in the UK should take the following steps before their arrival date:
Identify the relevant case. Determine which of Cases 4–8 will apply based on your circumstances — employment, accommodation, and prior UK residency history all matter.
Establish the split date precisely. The split date determines from which point UK income tax applies in full. Even a difference of a few weeks can affect the tax treatment of significant income items — a bonus paid just before vs. just after the split date can have materially different tax consequences.
Review your investment portfolio. Capital gains on non-UK assets during the overseas part of the arrival year are not subject to UK CGT. If you have significant unrealised gains on overseas assets, it may be worth considering whether to crystallise them before or early in the overseas part, before full UK residence begins.
Ensure employment contracts are correctly structured. If the start of full-time UK employment determines the split date (Case 5), the contractual commencement date is critical.
Practical Considerations for Departing Individuals
For those leaving the UK:
Do not assume split year applies automatically. HMRC does not grant split year treatment without a claim, and many individuals discover retrospectively that a case did not apply.
The 91-day rule in the overseas part matters. Several departure cases require that you spend fewer than 91 days in the UK during the overseas part of the year. Family visits, business trips, and other UK stays all count.
Capital gains before departure. Assets with large unrealised gains might be better crystallised before the split date if the overseas part would otherwise push the gain into the following non-resident year — particularly because non-resident CGT does apply to UK residential property regardless.
Income in the year of departure. Bonuses, share vesting, and other lump sums paid in the UK part of the departure year remain fully taxable. Timing can make a significant difference.
Tax Returns and Claiming Split Year Treatment
Split year treatment is claimed on the Self Assessment tax return for the relevant year, in the residence section. HMRC's SA109 supplementary pages must be completed, including identification of the case relied upon and the split date.
HMRC may enquire into split year claims, particularly where the application of conditions is borderline. It is advisable to document the factual basis for the claim carefully at the time, including records of travel, accommodation arrangements, and employment start dates.
How Global Investments Can Help
Getting split year treatment right can make a material difference to the UK tax position in the year of arrival or departure. Errors — in either direction — can result in unexpected tax bills or missed planning opportunities. Global Investments works with internationally mobile individuals to:
- Determine whether split year treatment applies and identify the correct case
- Plan the timing of arrivals, departures, asset disposals, and income recognition to make best use of the split year rules
- Ensure that Self Assessment returns are completed accurately and that claims are properly documented
- Coordinate with overseas tax advisers to ensure the split year position is consistent with the tax position in the destination or origin country
Tax treatment depends on individual circumstances and may change in future. This guide reflects the law as of June 2026, but SRT rules and HMRC practice evolve — always seek qualified professional advice for your specific circumstances.
Contact Global Investments to discuss your move to or from the UK and ensure your split year position is correctly handled.
This guide is for general information only and does not constitute financial advice or a personal recommendation. The value of investments can fall as well as rise and you may get back less than you invest. Tax rules, pension legislation, and investment regulations change — always verify current rules and seek advice from a qualified independent financial adviser before making any financial decisions.