Split-year treatment: going non-resident mid-tax-year
You don't have to wait until 6 April. Leave part-way through the year, meet a Case, and the clock on UK tax on your foreign earnings stops on your split date — legally, and reported on your tax return.
Split-year treatment divides the tax year you leave into a UK part (taxed as resident) and an overseas part (taxed, for most purposes, as non-resident) — so foreign income and gains arising after you go fall outside UK tax. You must be UK-resident for the whole year under the Statutory Residence Test, then meet one of the eight Cases (HMRC RDR3; RFIG21010; 2026/27).
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Your split year, on the calendar
UK part
Taxed as UK resident — worldwide income & gains.
Overseas part
Taxed (for most purposes) as non-resident — foreign income & gains drop out.
The tax year (6 April → 5 April) divides at your split date. The UK part (before the split) is taxed as resident on worldwide income; the overseas part (after) is taxed for most purposes as non-resident, so foreign income and gains arising then fall out of UK tax. UK-source income remains taxable throughout. Case 1 splits where overseas work begins; Case 3 splits where you give up your last UK home.
Maps Case 1 vs Case 3 onto a real calendar. Source: HMRC RFIG21010, RFIG21080, RFIG21140.
What is split-year treatment — and what is it not?
Split-year treatment splits the tax year you leave into a UK part and an overseas part. In the UK part you're taxed as a UK resident on your worldwide income and gains; in the overseas part you're taxed, "for most purposes", as a non-resident — so foreign income and gains arising after you go fall outside UK tax (HMRC RFIG21010). It is a relief written into the law, not a loophole.
Under the SRT you are, in principle, either UK resident or non-resident for an entire tax year — there's no "half-resident". Split-year treatment is a relieving overlay on top of that all-or-nothing rule (Finance Act 2013, Schedule 45, Part 3).
What it is not:
- Not a way to make the whole year tax-free. The UK part is fully taxable as resident. Only the overseas part's foreign income and gains drop out — and even then, UK-source income stays in charge.
- Not automatic in the sense of "no action". It applies if you meet a Case, but you must positively report it on your tax return.
- Not UK-side magic that binds another country. It does not override a double-tax-treaty tie-breaker, nor stop your new country taxing you under its own rules. See the double-tax-treaty tie-breaker guide.
- Not a substitute for the SRT. It lives downstream of the test. If the SRT already makes you non-resident for the year, there is nothing to split.
Do you have to wait until 6 April to become non-resident?
No. That's the point. If you leave part-way through the year and meet one of the Cases, your tax year splits on your departure date — your post-departure foreign income and gains fall out of UK tax from then, not from the next 6 April (HMRC RFIG21010). The catch: you must be UK-resident for that whole year first, and non-resident the following year. Without split-year treatment, leaving in August would leave your foreign earnings from August to the following April exposed to UK tax. See the UK tax year explained.
What is the precondition — resident for the year, then a Case?
Before you reach any Case, the SRT must already have made you UK resident for the whole tax year. Only then do you ask whether the year splits. If the SRT makes you non-resident, there's nothing to split (HMRC RFIG21030). Run it in two steps:
- Run the SRT for the departure year — automatic overseas tests, automatic UK tests, then sufficient ties, in that order. See the Statutory Residence Test, or check your status.
- If — and only if — the SRT says you're resident for the whole year, test the split-year Cases below.
Three consequences: split-year can apply only in the year of departure; a year can be a split year at most once; and you must be non-UK resident for the following tax year for any leaver Case to apply (RFIG21040, 21090, 21130).
Which split-year Cases matter when you're leaving?
Of the eight Cases, three apply to people leaving. Where you meet more than one, priority runs Case 1 over Case 2 over Case 3 (HMRC RFIG21030).
| Case | Who it's for | Trigger | What fixes the split date |
|---|---|---|---|
| Case 1 | Overseas-job mover / relocating employee | Starting full-time work overseas | First day you do >3 hours' work overseas |
| Case 2 | Trailing partner | Partner of someone in Case 1 | Later of joining your partner abroad / their Case 1 split date |
| Case 3 | Home-leaver, nomad, freelancer | Ceasing to have any home in the UK | The day you give up your last UK home |
Case 1 — starting full-time work overseas
The clean break for the Dubai mover and the relocating employee. You must be UK resident this year and last year, non-resident next year (because you meet the third automatic overseas test), and there must be a "relevant period" from your first day of >3 hours' overseas work to 5 April throughout which you meet the overseas-work criteria (HMRC RFIG21040, RFIG21050). The permitted UK days and UK-workdays shrink the longer you wait to leave:
| Whole months to overseas work | Permitted UK days | Permitted UK workdays (>3 hrs) |
|---|---|---|
| 0 | 90 | 30 |
| 3 | 67 | 22 |
| 6 | 45 | 15 |
| 7 | 37 | 12 |
| 9 | 22 | 7 |
| 11 | 7 | 2 |
The split date for Case 1 is the first day you do more than 3 hours of work overseas (HMRC RFIG21080).
Case 2 — partner of someone working overseas
The trailing partner who moves so the couple can keep living together. You must be UK resident this year and last, non-resident next; your partner's year must fall within Case 1; you move overseas to continue living together; and from your deemed departure day you have no UK home (or spend the greater part of your time in the overseas home) and stay within the same pro-rated UK-day limits as Case 1 (no separate workday sub-limit) (HMRC RFIG21090). The split date is the later of joining your partner abroad and the start of their Case 1 overseas part (RFIG21110).
Case 3 — ceasing to have a home in the UK
The route for the home-leaver with no qualifying overseas job. All must hold (HMRC RFIG21130):
- You are UK resident this year, were resident last year, and non-resident next year.
- You had a UK home at the start of the year and cease to have any UK home for the rest of it.
- From the day you cease to have a UK home to 5 April, you spend fewer than 16 days in the UK.
- Within 6 months you establish a sufficient link to one overseas country.
The split date for Case 3 is the day you cease to have any home in the UK (HMRC RFIG21140).
What happens to your income — foreign vs UK-source?
In the overseas part your foreign income and gains arising then drop out of UK tax — but UK-source income stays taxable. Split-year removes the worldwide basis of charge for the overseas part; it does not switch off UK tax on UK-sourced income (HMRC RFIG21010).
| Falls OUT of UK tax (overseas part) | Stays TAXABLE (UK-source) |
|---|---|
| Overseas employment income for duties abroad | UK employment income for UK workdays |
| Overseas self-employment profits | UK property / rental income (NRL Scheme) |
| Foreign interest, dividends and rental | UK pensions and certain annuities |
| Gains on non-UK assets disposed of then | Gains on UK land and property (60-day report) |
How do you claim split-year treatment?
You claim it on the SA109 "Residence" pages, filed with your Self Assessment return (the SA100): tick box 3 to claim split-year treatment, tick box 3.1 if more than one Case applies, and enter your split date in box 6. It is not automatic — you must report it (HMRC SA109 (2026); 2026/27).
| SA109 box | What it does |
|---|---|
| 1 | Tick if you were not resident in the UK for the year |
| 3 | Tick to claim split-year treatment — the claim box |
| 3.1 | Tick if more than one Case applies |
| 4 | Tick if you were resident in the UK for the previous year |
| 6 | Enter the date the UK part begins or ends — the split date |
| 7 | Tick if you meet the third automatic overseas test (Case 1) |
| 10 / 12 | Days spent in the UK / number of UK ties |
| 54 | Free-text "Any other information" — name the Case and explain |
- The SA109 cannot use HMRC's free online service: it's paper SA100 + SA109 by post (deadline 31 October), or commercial software / an agent (online, deadline 31 January).
- If you're not in Self Assessment for the departure year, you don't file an SA109 — you tell HMRC on a P85. And because leaving mid-year often means HMRC over-taxed you, check your UK tax refund after leaving.
Worked examples
Illustrative, dated 2026/27, tied to the verified rules above — not advice.
Example 1 — Case 1, the Dubai mover
Aisha starts a full-time Dubai job and does her first day of >3-hours overseas work on 6 November 2026 — seven whole months after 6 April. Her year splits on 6 November: the UK part runs 6 April to 5 November (taxed as resident), the overseas part from 6 November (non-resident). She must stay within 37 UK days and 12 UK-workdays. Her UAE salary from 6 November is outside UK tax — but UK rental income and any future UK property sale stay taxable.
Example 2 — Case 3, the home-leaver
Marco, a freelancer, completes the sale of his only UK home on 24 September 2026 and moves to Lisbon. From that date he spends fewer than 16 UK days, and within 6 months is tax-resident in Portugal. His year splits on 24 September under Case 3. His foreign freelance income from then falls out of UK tax — but any work physically done on UK days remains UK-source.
Example 3 — priority, Case 1 over Case 3
Theo gives up his UK flat in May and starts full-time work overseas in July, meeting both Cases. The priority rule means Case 1 governs — so his split date is the first day of overseas work (July), not the day he gave up the flat (May) (HMRC RFIG21030).
Build your leaving-the-UK checklist
Line up the SA109 (or P85), your split date, day records and continuing UK obligations in order.
Common questions
What is split-year treatment?
Split-year treatment divides the tax year you leave (or arrive) into a UK part (taxed as resident) and an overseas part (taxed, for most purposes, as non-resident), so foreign income and gains arising after you leave fall outside UK tax. You don't have to wait until 6 April. It applies only in your year of departure, and only if you meet one of the eight cases. (HMRC RFIG21010; RDR3; 2026/27.)
Do I have to wait until 6 April to become non-resident?
No. If you meet a split-year case, the tax year you leave splits on your departure date: the overseas part is taxed as non-resident, so your post-departure foreign income and gains fall out of UK tax. But you must be UK-resident for that whole year first, and non-resident the following year. (HMRC RFIG21010, RFIG21030; 2026/27.)
What are the split-year cases for someone leaving the UK?
Three leaver cases: Case 1, starting full-time work overseas; Case 2, partner of someone in Case 1; Case 3, ceasing to have any home in the UK. Priority runs Case 1 over Case 2 over Case 3. The case fixes the date your year splits. (HMRC RFIG21030–21140; FA 2013 Sch 45; 2026/27.)
What are the conditions for Case 3 split-year (ceasing to have a UK home)?
All must hold: you're UK-resident this year, were resident last year, and non-resident next year; you had a UK home at the start of the year and cease to have any UK home for the rest of it; from that date you spend fewer than 16 UK days; and within 6 months you establish a sufficient link to one overseas country. (HMRC RFIG21130; FA 2013 Sch 45 para 46; 2026/27.)
Does split-year treatment make my overseas income tax-free?
Not entirely. Split-year removes the worldwide basis of charge for the overseas part, so foreign income and gains arising then fall out of UK tax — but UK-source income stays taxable: UK workdays, UK rental, UK pensions, and gains on UK land. It changes when the clock starts, not whether UK-source tax applies. (HMRC RFIG21010; RDR3; 2026/27.)
How do I claim split-year treatment?
You claim it on the SA109 "Residence" pages filed with your Self Assessment return — tick box 3, tick box 3.1 if more than one case applies, and enter the split date in box 6 (explain the case in the free-text box 54). It is not automatic; you must report it. (HMRC SA109 (2026) form and notes; 2026/27.)