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Residence & Tax Planning

TAX ADVISER & ACCOUNTANT | HMRC AUTHORISED AGENT | COMPANIES HOUSE ACSP

London | Serving individuals and companies in the UK and overseas

25+ Years' Experience | ICO Registered | HMRC AML Supervised

Tax residence determines which income and gains are taxable in the UK. Since 6 April 2025, domicile no longer governs the treatment of foreign income: a residence-based regime applies, with elections that must be made in the tax return and time limits that cannot be recovered once missed.

The UK tax position of individuals arriving in or leaving the UK

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What determines your position

Residence is a statutory test. The Statutory Residence Test considers days spent in the UK, work patterns and ties to the UK, including family, accommodation and time spent in previous years. The number of days alone rarely decides the outcome.

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A year can be split. Where specific conditions are met, split year treatment divides the year of arrival or departure into a UK part and an overseas part, so that income from the overseas part is not taxed in the UK.

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New residents may claim the FIG regime. Individuals who become UK resident after at least ten consecutive tax years of non-residence can elect for foreign income and gains to be exempt for their first four years of residence. The election is made in the tax return for each year.

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The remittance basis has ended. From 6 April 2025, the remittance basis is no longer available. Former users may bring previously untaxed foreign income and gains to the UK at a reduced rate under the Temporary Repatriation Facility, available for a limited period.

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Inheritance Tax follows residence. Exposure to UK Inheritance Tax on worldwide assets now depends on long-term residence, generally ten of the previous twenty tax years, rather than domicile.

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Treaties can change the result. Where an individual is resident in both the UK and another country, a double tax treaty may determine where they are treated as resident and how tax paid abroad is relieved.

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A short absence may not be enough. Individuals who leave the UK and return within five years may be taxed on certain income and gains received while non-resident.

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Residence, the FIG regime and the tax position of internationally mobile individuals form part of the practice's work. Each position is established from the facts of the individual's circumstances before any return or election is filed. All matters are handled in confidence.

The matters we handle

Statutory Residence Test assessment for UK tax residence based on days, work and UK ties.

Statutory Residence Test

Assessment of residence status for the year, based on days, work and ties, with the position set out in writing.

UK arrival tax planning covering split year treatment, the four-year FIG regime and foreign income.

Arrival in
the UK

Split year treatment, eligibility for the four-year FIG regime and the tax position of income arising abroad.

UK arrival tax planning covering split year treatment, the four-year FIG regime and foreign income.

Departure from the UK

Split year treatment, non-resident status, temporary non-residence rules and the treatment of UK income after leaving.

UK departure tax planning covering split year treatment, non-resident status and temporary non-residence rules.

FIG regime
elections

Eligibility, the income and gains covered, and the elections required in each tax return.

FIG regime election review covering eligibility, qualifying foreign income and gains, and tax return elections.

Former remittance basis users

The Temporary Repatriation Facility, rebasing of foreign assets and the transition to the new regime.

Dual residence and tax treaty advice covering treaty residence, foreign tax relief and overseas income reporting.

Dual residence and treaties

Treaty residence, relief for tax paid abroad and the reporting of overseas income in Self Assessment.

From facts to filing

 01

SUBMISSION

Provide travel dates, details of work, family and accommodation, and sources of income.

 02

REVIEW

Days, ties, residence history and income sources are examined against the statutory tests.

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WRITTEN OPINION & TERMS

A written opinion sets out the residence status, the regimes and elections available, and the scope and fees of the work.

 04

FILING

Returns, elections and treaty claims are prepared and filed.

 05

FORWARD POSITION

The position for future years is recorded, including the time limits for elections and regime periods.

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Residence decides what the UK can tax.
Submit your circumstances for a written assessment of your position.

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