Double taxation and the UK
Your life spans two countries; your tax bill should not double. See which country may tax your salary, pension, dividends and property, and how the other one gives way.
| The treaties | published country by country in the GOV.UK tax treaties collection |
| Dual residence | tie-breaker: permanent home, centre of vital interests, habitual abode, nationality |
| Salary | short stays of up to 183 days can stay taxable at home if conditions are met |
| Relief | full relief, partial relief or credit, claimed on HMRC forms HS302 or HS304 |
| Inheritance | separate conventions with six countries only |
| Updated | November 2026 |
How a treaty decides
A double taxation agreement shares out taxing rights. First it settles where you are resident when both countries claim you, say because you work in London while your family lives in Copenhagen. Then it assigns each type of income to one country, and the other credits the tax or exempts the income. A claim under the UK's FIG regime does not change your residence under the treaty.
The UK's treaties follow a common pattern, but they differ in details that cost money: the period over which the 183 days for salary are counted, the treatment of pensions, the rate on dividends and the rules for property-rich companies. So the general principles come first, in our piece on the UK's tax treaties, and then the text of your own treaty.
Social security is not covered by tax treaties. For people moving between the UK and the EU it is coordinated under the EU-UK Trade and Cooperation Agreement; other countries have their own arrangements with the UK. And if you hold shares or a business when you move, check your home country's departure rules before you go.
The articles on double taxation
Frequently asked questions
I work in London and my family lives at home. Where am I resident?
If both countries treat you as resident, the treaty decides in a fixed order: first the permanent home, and if you have one in both countries, the centre of vital interests. Family and home weigh heavily. After that come habitual abode and nationality.
Who taxes my pension if I live in the UK?
For most work pensions the UK's treaties give the right to tax to the country where you live, so the UK. Some pensions fall under other articles, so check which one covers yours, and apply for relief in the paying country where the treaty requires it.
Does the treaty cover inheritance tax?
No. Income tax treaties do not cover estates. The UK has separate estate and gift tax conventions with only six countries: Ireland, South Africa, the United States, the Netherlands, Sweden and Switzerland, plus older estate duty treaties with France, Italy, India and Pakistan.
Two countries, one tax bill: your case under the treaty
In the UK Tax Consult we check where you are resident under the treaty, who taxes your salary, pension and investment income, and how the relief works. By phone, Zoom or Signal.