| Basic rule | resident or not, always for the whole tax year (6 April to 5 April) |
| Split year | divides the year into an overseas part and a UK part |
| Cases | 8 cases: 1 to 3 for leaving, 4 to 8 for arriving |
| Choice | none: if the conditions are met, the split applies |
| Allowances | in full in the year of arrival, even with a split year |
| FIG regime | a split year counts as a full year of residence |
| Updated | November 2026 |
What a split year is
Under the statutory residence test you are either resident for a tax year or not, and for the whole year. Move to Bristol in October and, without another rule, you would be resident back to 6 April, with your worldwide income since the spring.
Split year treatment divides that year in two: an overseas part, in which you are treated for most purposes as non-resident, and a UK part, in which you are taxed as a normal resident. Put simply, you pay UK tax on foreign income and gains only so far as they arise in the UK part. For foreign pensions the law says so expressly.
Two things surprise many people. First, you have no choice: meet all the conditions of a case and the split applies, whether you want it or not. Second, despite the split you get your allowances in full in the year you arrive, including the full personal allowance.
The five cases for arriving
In every arrival case you are resident under the SRT in the year you arrive and were not resident the year before. If you were abroad for less than a full tax year, there is no split year.
| Case | For whom | Key conditions | UK part starts |
|---|---|---|---|
| Case 4 | You move to the UK for good | From a day in the year your only home is in the UK (or all your homes are), until the end of the year; no sufficient ties before | on the day you first meet the only home test |
| Case 5 | You start full-time work in the UK | From a day you meet the third automatic UK test (365 days of full-time work in the UK); no sufficient ties before | on the first day of that 365-day period |
| Case 6 | You come back after full-time work abroad | Non-resident the year before because of full-time work abroad, resident in one of the 4 years before that, resident the following year | after the last day of full-time work abroad |
| Case 7 | The partner of someone in case 6 | You move to the UK to live with your returning partner; resident the following year | on the day you arrive |
| Case 8 | You have a UK home from a certain day, perhaps keeping one abroad | UK home until the end of the year and throughout the next; the next year is resident and not a split year; no sufficient ties before | on the day you first have a home in the UK |
HMRC, RFIG21150 to RFIG21280
Which case applies to you
The typical newcomer from elsewhere in Europe lands in case 4, 5 or 8. Case 4 fits if you give up your home abroad and live only in the UK. Case 5 fits if a full-time UK job is the reason for the move. Case 8 is the catch-all for anyone who starts a UK home and perhaps keeps the old one, but it requires the whole of the next year to be British too.
For the part of the year before the split date, cases 4, 5 and 8 ask whether you already had sufficient ties. For that check the day limits of the ties table shrink pro rata. Arrive in October, for example, and the limits of 15, 45, 90 and 120 days become 9, 26, 52 and 70 days. Spend two months house-hunting in the UK in early summer and you can lose the split.
If several cases fit, priority rules decide the case and the date, usually in favour of the earliest split date, which means the shorter overseas part. You state the case in your tax return. For tax treaties, by the way, a split year changes nothing: whether you are UK resident for treaty purposes is still decided by the treaty's tie-breaker, as explained in the UK's tax treaties.
How to check your year of arrival
Four questions, in this order.
- 1
1. Are you resident in this tax year at all?
The automatic overseas tests come first. If you were not resident in the three previous years and spend fewer than 46 days of the tax year in the UK, you are non-resident for the whole year. Then you need no split year.
- 2
2. Were you non-resident the year before?
Otherwise there is no arrival case. If you were away only briefly, you stay in the system.
- 3
3. Which case fits, and from which day?
Your home, the start of work or your partner's return sets the day. Check the reduced ties limits for the period before it.
- 4
4. What follows next year?
Cases 6, 7 and 8 require you to be resident the following year too; case 8 even without a split and with a UK home throughout.
Split year and the FIG regime: the used-up year
This is where the most expensive surprise lies. The four-year FIG regime covers up to four consecutive tax years from the year you become resident. A split year counts as a full year of residence for this, even though it has an overseas part. Arrive on 1 March with a split year and you have spent year one of your four FIG years on five weeks of British life.
The year is not entirely lost: thanks to the split you usually pay nothing on foreign income of the overseas part anyway, and you can make the FIG claim for taxable foreign income of the UK part. But the window closes sooner.
The alternative is a late move. Arrive only in the last six weeks before 5 April, having been non-resident in the three previous years, and together with earlier visits in the same tax year you may stay under 46 days. Then the second automatic overseas test makes you non-resident for the whole year, and your four FIG years start on 6 April. Count every midnight for this, including those on viewing trips in the autumn. What you can do with your pension and portfolio in those four years is in pensions and investments in the UK.
The three cases for leaving
For the year you leave the UK there are cases 1 to 3. Case 1 applies if you start full-time work abroad and are non-resident the following year under the third automatic overseas test. Case 2 applies to the partner who goes with you. Case 3 applies if you give up your UK home, then spend fewer than 16 days in the UK and become tax resident in, or have your home in, the new country within 6 months. More, including temporary non-residence, in leaving the UK.
Frequently asked questions
Do I have to apply for split year treatment?
No, it applies automatically if you meet all the conditions of a case. You state the case in your Self Assessment return.
Do I get only part of the personal allowance in my year of arrival?
No. If you are resident for the tax year, you get the allowances in full, even with a split year. It is different if you claim the FIG regime for the year: then you lose the personal allowance and the CGT annual exempt amount.
What happens to capital gains in the year I arrive?
In the UK part the normal capital gains tax rules apply. A gain in the overseas part is generally not taxable in the UK. The main exceptions are disposals of UK residential property and assets of a UK branch.
I lived in the UK twelve years ago. Does the split year help me with the FIG regime?
For the FIG regime you need at least ten consecutive tax years of non-residence before the year you arrive. A split year when you left last time counts as a full year of residence, so count from the year after.
Sources: GOV.UK: RDR3 Statutory Residence Test (SRT) notes, section 6 Split years; HMRC Manual: RFIG21000 Split year treatment; HMRC Manual: RFIG21030 When split year treatment will apply; HMRC Manual: RFIG21150 Case 4; HMRC Manual: RFIG21270 Case 8; HMRC Manual: RFIG44000 Qualifying new resident; GOV.UK: RDR1 Residence, domicile and the remittance basis; GOV.UK: Tax on foreign income
