# Split-year treatment: tax year of relocation to the UK > How UK split-year treatment divides the tax year of relocation into UK and overseas parts: eight SRT cases, automatic application, and common pitfalls. Author: Мария Плотникова — юрист, Family Office (https://wiki.private.law/authors/plotnikova) Last modified: 2026-07-17T02:28:00.000Z Canonical: https://wiki.private.law/en/split-year-treatment Topics: investments Jurisdictions: uk Semantic tags: tax-regime --- The UK Statutory Residence Test (SRT) determines [UK tax residence](https://wiki.private.law/en/uk-tax-residence) for an entire year at once: a person is considered resident either for the whole year or not at all. In the year of relocation—into or out of the country—the "all or nothing" principle penalizes those who lived in the country for only part of the year. Split-year treatment smooths this out: the tax year, running from 6 April to 5 April, is divided into UK and overseas parts, and foreign income for the "overseas" half falls outside UK tax. ## Origin of the regime Before 2013, UK residence relied on case law and HMRC guidance booklet IR20: the criteria were vague, and disputes with HMRC dragged on for years. SRT replaced this with a [system of formal tests](https://wiki.private.law/en/tax-residency-basics) and simultaneously codified split-year, which had previously existed as extra-statutory concessions (ESC A11 and related). Today, year splitting is enshrined in law and operates according to clear criteria; inspector discretion has been removed from the process. The link to the UK tax year running from 6 April to 5 April explains the need for the regime: relocation almost never falls exactly on this boundary, and without split-year a person would pay UK tax on foreign income for months when they were already or still living in another country. ## Concept: the year is divided into two parts When conditions are met, the year is split into a UK part, where the person is taxed as a full resident—UK tax on [worldwide income](https://wiki.private.law/en/uk-tax-residence-worldwide-taxation) and gains—and an overseas part, where for most purposes they are treated as non-resident and pay tax only on UK sources (plus non-resident CGT on UK property). Resident status for the year is preserved; what changes is the basis on which foreign income is taxed in each part. The boundary between parts is the date of actual relocation; this is determined by the rules of the specific case, whereas a passport stamp or flight ticket date determines nothing by itself. ## When it applies: eight cases Split-year is available only to someone who is resident under SRT for that year and whose situation fits one of eight cases prescribed in law. Three cases are designed for departure, five for arrival. Each has its own conditions: nature of employment and number of working hours, presence or absence of a home in the UK, residence status in the previous and following years, and strict limits on days in the country. The case also determines the date on which the year is divided in two. ### On departure from the UK - Case 1 — starting full-time work overseas. - Case 2 — partner of someone who has started full-time work overseas. - Case 3 — ceasing to have a home in the UK. ### On arrival in the UK - Case 4 — acquiring a home only in the UK. - Case 5 — starting full-time work in the UK. - Case 6 — returning after full-time work overseas. - Case 7 — partner of someone who has ceased full-time work overseas. - Case 8 — acquiring a permanent home in the UK. > ⚙️ The cases themselves rest on numbers. For employment (Cases 1, 2, 6), an average of 35+ hours of work per week is required without significant break—that is, without a pause of 31 days or more—no more than 30 working days in the UK, and proportionally no more than 90 days of presence during the "overseas" part of the year. Case 3 is stricter: after giving up a UK home, no more than 15 days in the country are permitted, and within six months one must establish oneself abroad. Case 5 requires at least 75% of working days to fall in the UK. One day over the limit cancels split-year for the entire year, so counting is taken literally. > 🧭 If several cases fit the situation simultaneously, the law sets a priority for which one applies. Split-year occurs automatically when conditions are met—you cannot choose it at will. ## Typical scenarios In practice, almost everything comes down to a few recognizable situations. A senior manager leaves mid-year for full-time work abroad—this is Case 1, and the year splits from the first day of overseas work; a spouse relocating afterward falls under Case 2. Someone sells their UK home and moves to live in another country—Case 3. On the arrival side: a specialist takes up full employment in London—Case 5; an expat returns home after a multi-year contract abroad—Case 6; someone who acquires accommodation in the UK while keeping a home abroad—Case 8. There is no need to claim split-year separately—it is reflected in the annual Self Assessment return on the residence pages SA109. ## What split-year does not do Year splitting softens taxation of foreign income and gains for the "overseas" part, but does not cover everything. A number of UK sources—for example, income from property or work in the country—are taxed for the whole year regardless of split-year. The temporary non-residence rule can retrospectively tax dividends and certain gains if a person was non-resident for less than five full years. And the split itself operates only within the UK system: another country is not obliged to recognize it and may consider the person its own resident for the same period—in which case the outcome is determined by the [tie-breaker](https://wiki.private.law/en/tax-residency-tiebreaker) in the tax treaty. ## Pitfalls > 🔗 **Related** > [UK tax residence](https://wiki.private.law/en/uk-tax-residence) · [Tax residency basics](https://wiki.private.law/en/tax-residency-basics) · [Tie-breaker and dual residence](https://wiki.private.law/en/tax-residency-tiebreaker) · [UK deemed domicile](https://wiki.private.law/en/uk-deemed-domicile) · [Exit taxes](https://wiki.private.law/en/exit-taxes-overview) · [FIG regime (non-dom 2025)](https://wiki.private.law/en/uk-non-dom-2025) · [Remittance basis after 2025](https://wiki.private.law/en/uk-remittance-basis-after-2025) · [UK and worldwide income](https://wiki.private.law/en/uk-tax-residence-worldwide-taxation) The main pitfalls are the technical definition of "home" and careful counting of days, on which both SRT status itself and the split date depend. An empty but available UK flat still counts as a "home" and easily destroys Case 3. HMRC counts the day of arrival and day of departure by presence at midnight, so short visits accumulate faster than it seems. An error in the relocation date shifts the boundary between parts of the year and changes the tax amount. Before changing country, it is sensible to model both scenarios—with and without split-year—and check conditions against HMRC guidance: from 2025 the former RDRM compendium has been renamed [Residence and FIG Regime Manual](https://www.gov.uk/hmrc-internal-manuals/residence-and-fig-regime-manual) (RFIG), and the reference point for the test itself remains note [RDR3](https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt). ## What changed from 6 April 2025 The 2025 reform reshaped the context around split-year without touching its mechanics. From 6 April 2025, the UK abolished non-dom status and [remittance basis](https://wiki.private.law/en/uk-remittance-basis-after-2025), and with them the link between tax and domicile. Their place was taken by the [FIG regime](https://wiki.private.law/en/uk-non-dom-2025) (foreign income and gains): someone who was non-resident for ten consecutive years can, for the first four years of UK residence, avoid paying tax on foreign income and gains, even when bringing those funds into the country. For a new arrival, the two mechanisms combine: split-year takes the "overseas" part of the year of entry out of tax, and FIG covers the next four full years. The test for the split date and the eight cases remained the same—what changed is what happens to foreign income already within the UK part. > 🍓 Split-year treatment divides the tax year of relocation into UK and overseas parts. It occurs automatically under one of eight cases, softens tax on foreign income for the "overseas" part, and applies only if the person remains resident under SRT for the year. *This material is for informational and analytical purposes and does not replace individual legal or tax advice.* --- --- ## Factual claims - Before 2013, UK residence relied on case law and HMRC guidance booklet IR20: the criteria were vague, and disputes with HMRC dragged on for years. - Split-year is available only to someone who is resident under SRT for that year and whose situation fits one of eight cases prescribed in law. - The 2025 reform reshaped the context around split-year without touching its mechanics.