Split Year Treatment Explained: All 8 Cases (2026)

Split year treatment divides a single UK tax year into a UK part and an overseas part, so that you are taxed as a UK resident for only part of it. It exists because the Statutory Residence Test works on whole tax years: if you move abroad - or move to the UK - part-way through a year, the test will typically still classify you as UK resident for the entire year. Split year treatment corrects that. There are 8 cases, Cases 1-3 for people leaving and Cases 4-8 for people arriving, and if you meet the conditions of one it applies automatically - there is no choice in the matter.

Key points

• Split year treatment only applies if you are UK resident for the year - it splits that year, it does not make you non-resident
• There are 8 cases in total: Cases 1–3 for people leaving the UK, Cases 4–8 for people arriving
• If you qualify, the treatment must be applied - it is not optional
• The date at which the year splits varies by case and depends on your specific circumstances
• Split year treatment does not affect your position under a double taxation treaty

Why split year treatment exists

Under the Statutory Residence Test, your residence status is determined for a whole tax year - you are either UK resident or non-resident for the full year. Without split year treatment, someone who moved abroad on 1 July would be UK resident for the entire year, taxed on worldwide income from 6 April through to 5 April, even though they had been living overseas for most of it.

Split year treatment was introduced to prevent this outcome. It divides the year at a defined point:

• UK part: you are taxed as a UK resident - on worldwide income
• Overseas part: for most purposes you are taxed as a non-resident - generally only UK-source income is in scope

Per RFIG21010, if the conditions of a case are met, the split applies. The individual has no discretion over whether it applies.

The 8 cases: overview

HMRC defines 8 distinct circumstances in which split year treatment can apply (RFIG21030).

Leaver cases - you are UK resident and go overseas mid-year:

Arriver cases - you were non-resident and come to the UK mid-year:

For most people leaving the UK, one of Cases 1–3 will apply. The conditions for each are different and non-interchangeable.

Case 1: Starting full-time work overseas

This is the most common case for people relocating for employment or taking a contract abroad.

Conditions (RFIG21040):

• You are UK resident for the tax year in question
• You were UK resident for the previous tax year
• You are non-UK resident in the following tax year because you meet the third automatic overseas test (full-time work abroad) - even if you also meet the first automatic overseas test that year
• You satisfy the overseas work criteria during a "relevant period"

What is the relevant period? It is a period that begins with a day in the current tax year on which you do more than 3 hours of overseas work, and runs to the end of the tax year (RFIG21050). In practice, it starts on your first day of overseas work.

The overseas work criteria (RFIG21060):

• You work full-time overseas throughout the relevant period
• No significant break from overseas work during that period
• You do not work in the UK for more than 3 hours on more than the permitted number of days
• You spend no more than the permitted number of days in the UK

The permitted limits depend on when the relevant period starts. HMRC publishes a table at RFIG21070 giving the permitted UK days (column Y) and permitted UK working days (column X) based on the start month of the relevant period:

When does the overseas part start? On the first day of the relevant period - i.e., the first day you do more than 3 hours of overseas work.

Worked example: Sarah leaves for Dubai

Sarah has lived and worked in London her entire career. In the 2024–25 tax year she accepts a three-year employment contract in Dubai. Her first day of work in Dubai is 1 September 2024.

She returns to the UK once, in January 2025, for 10 days - 8 of which are UK working days. She flies back to Dubai on 20 January and works there until 5 April 2025.

Checking the conditions:

• UK resident for 2024–25? Yes - she has not spent enough time abroad before 5 April 2025 to pass the automatic overseas tests for the full year
• UK resident for 2023–24? Yes
• Non-UK resident for 2025–26 via the third automatic overseas test? She will work full-time in Dubai throughout 2025–26 - yes
• Overseas work criteria from 1 September 2024 to 5 April 2025?
  • Relevant period starts in September → permitted limits: X = 17 UK working days, Y = 52 UK days
  • Sarah spent 10 days in the UK - within the 52-day limit ✓
  • She worked in the UK for 8 days - within the 17-day limit ✓
  • No significant break from overseas work ✓

Result: Sarah qualifies for Case 1 split year treatment. Her UK part runs from 6 April 2024 to 31 August 2024. Her overseas part runs from 1 September 2024 to 5 April 2025. UK-source income earned during the overseas part (such as rental income from a UK property) remains taxable in the UK; her Dubai employment income does not.

Case 2: Partner of someone starting full-time work overseas

If your partner qualifies for Case 1 (in the same year or the previous year), and you move overseas to live with them, you may qualify for Case 2 - even if you are not working yourself.

Key conditions (RFIG21090):

• UK resident this year and the previous year
• Non-UK resident the following year
• Your partner meets Case 1 this year or the previous tax year
• You were living together in the UK at some point in this or the previous tax year
• You move overseas specifically to continue living together while your partner works there
• From your deemed departure day: no UK home (or, if you retain one, you spend the greater part of your time in the overseas home), and you stay within the permitted UK day limits

Deemed departure day (RFIG21110): the later of:

• The day you join your partner overseas to live together
• The first day of your partner's overseas part (their Case 1 split date)

Example: Tom is Sarah's husband. He moves to Dubai on 15 October 2024 to live with her. Sarah's Case 1 split date is 1 September 2024. Tom's deemed departure day is the later of 15 October and 1 September - so 15 October 2024. His UK part ends on 14 October; his overseas part starts on 15 October.

Case 3: Ceasing to have a UK home

Case 3 applies to people who leave the UK without necessarily working full-time abroad - for example, moving to be with a partner overseas, or retiring.

Key conditions (RFIG21130):

• UK resident this year and the previous year
• Non-UK resident the following year
• Had a UK home at the start of the tax year
• Ceases to have any UK home at some point during the year

From the point you cease to have a UK home, you must also:

• Spend fewer than 16 days in the UK for the rest of the tax year
• Within 6 months: become tax resident in another country, be present there at the end of each day for 6 months, or have your only home there

When does the overseas part start? On the day you cease to have a UK home.

The HMRC example (RFIG21140): Maureen moves out of her UK flat on 24 September 2014 and flies to the UAE. She has no close family in the UK and does not return before 5 April 2015. Her overseas part starts on 24 September - the first day she had no UK home.

Important: the 16-day limit after ceasing to have a UK home is strict. A couple of brief return visits in the remaining months of the year could easily breach it, disqualifying Case 3 entirely.

Priority rules

If your circumstances fit more than one case, priority rules determine which case applies and what date the year splits from (RFIG21030). The leaver and arriver rules work differently.

Leavers (Cases 1-3): a fixed hierarchy.

Case 1 > Case 2 > Case 3

Case 1 takes priority over both Case 2 and Case 3. Case 2 takes priority over Case 3.

Arrivers (Cases 4-8): resolved by date, not rank.

If you were not UK resident in the previous tax year and your circumstances fall within two or more of Cases 4-8, the tie is broken mainly by which case produces the earliest split year date - not by case number:

For Cases 4-8, the split year date means the final day of the overseas part of the year for that case. So the case that gives you the shortest overseas part wins, with Case 6 and Case 7 acting as tiebreakers where the dates are equal.

This matters more than it looks. It is common to satisfy Cases 4, 5 and 8 simultaneously - someone relocating to the UK for a job who also takes a UK home may meet all three - and which one applies determines the date your worldwide income becomes taxable here.

Cases 4–8: arriving in the UK

Cases 4–8 apply when you were non-UK resident in the previous tax year and come to the UK part-way through this one. The structure mirrors the leaver cases, reversed: the overseas part runs from 6 April up to your arrival trigger, and the UK part runs from that trigger to the end of the tax year.

Three of the five - Cases 4, 5 and 8 - share a requirement that catches people out: you must not have had sufficient UK ties during the overseas part of the year. Because that part is shorter than a full year, the normal day-count limits in the sufficient ties tables are scaled down in proportion to how much of the year has already run.

Reduced day-count limits for Cases 4, 5 and 8 (RFIG21150, RFIG21170, RFIG21270 - the table is identical in all three):

So if your trigger date falls in October, a 90-day limit becomes 52 days for the pre-arrival part of the year, and a 45-day limit becomes 26.

Case 4: Starting to have a UK home only

Case 4 is for people who arrive and end up with all of their homes in the UK - they give up the overseas home rather than keeping it.

Conditions (RFIG21150):

• You are UK resident for the tax year in question
• You were non-UK resident for the previous tax year
• You do not meet the only home test at the start of the tax year, but at some point during it you do, and you continue to meet it until the end of the tax year
• You do not meet the sufficient ties test for the part of the year before the day you meet the only home test, applying the reduced limits in the table above

What is the only home test? You meet it if you have only one home and that home is in the UK, or if you have more than one home and all of them are in the UK. Retaining a home overseas means you fail it - which is the dividing line between Case 4 and Case 8.

When does the UK part start? The overseas part runs from the start of the tax year to the day before the earliest point at which you meet the only home test. The UK part therefore begins on the day you first meet it, and runs to the end of the tax year (RFIG21160).

The HMRC example (RFIG21160): Olan has worked in Germany for five years and is not UK resident. He rents out his German apartment on a two-year lease from 27 May 2013 and moves to the UK on 1 June 2013 to look for work, staying in temporary accommodation. He signs a 12-month lease on a London apartment on 1 July 2013 and starts UK employment on 22 July.

Olan qualifies for Case 4 for 2013–14: he was non-resident in 2012–13, he started to have his only home in the UK during the year and kept it to the year end, and he had no UK ties between 6 April and 1 July. His overseas part ends 30 June 2013; his UK part starts 1 July 2013 - the day he started to have his only home in the UK, not the day he physically arrived.

Note that Olan might also have met Case 5 or Case 8. The priority rules resolve it in favour of whichever case gives the shortest overseas part.

Case 5: Starting full-time work in the UK

Case 5 is the mirror of Case 1 - the common route for someone relocating to the UK to take a job.

Conditions (RFIG21170):

• You are UK resident for the tax year
• You were non-UK resident for the previous tax year
• You meet the third automatic UK test (full-time work in the UK) over a period of 365 days
• You do not meet the sufficient ties test for the part of the year before the point you first meet the third automatic UK test, applying the reduced limits in the table above

When does the UK part start? The overseas part runs from the start of the tax year until the point you first meet the third automatic UK test; the UK part runs from there to the year end (RFIG21180). If there is more than one qualifying 365-day period, the UK part runs from the beginning of the first one.

The 365-day period does not have to sit inside the tax year, and it does not have to begin with full-time work - it only has to average out.

The HMRC example (RFIG21180): Andrea arrives from Poland on 20 May 2013 for a two-week visit and has never been UK resident. She is offered a hotel job and starts on 10 June 2013, working 20 hours a week for the first 8 weeks, then 40 hours a week from 5 August. She takes 20 days of leave in the year.

Testing the 365 days from 10 June 2013:

• Step 1: no disregarded days (no days working more than 3 hours overseas)
• Step 2: total UK hours = (8 weeks × 20) + (40 weeks × 40) = 1,760 hours
• Step 3: reference period = 365 − 0 disregarded − 20 days leave = 345 days
• Step 4: 345 ÷ 7 = 49.29, rounded down to 49
• Step 5: 1,760 ÷ 49 = 35.91 hours per week

That averages over 35 hours, so Andrea meets the third automatic UK test from 10 June 2013 - a day on which she worked more than 3 hours in the UK. Her UK part starts then, even though for her first two months she was working part-time.

Case 6: Ceasing full-time work overseas

Case 6 is for people returning to the UK after a period of full-time work abroad. It is the most condition-heavy of the arriver cases because it reaches back several years.

Conditions (RFIG21190):

• You are UK resident for the tax year in question
• You were not UK resident for the previous tax year because you satisfied the third automatic overseas test for that year (or, if that year was 2012–13, worked full-time overseas under the pre-SRT rules)
• You were UK resident for one or more of the 4 tax years before that non-resident year - so you may need to look back five years in total
• You are UK resident in the following tax year (whether or not that is itself a split year)
• You satisfy the overseas work criteria for a relevant period

What is the relevant period? Unlike Case 1, it starts at the beginning of the tax year and ends on a day in that year on which you do more than 3 hours of overseas work (RFIG21200).

The overseas work criteria (RFIG21210): during the relevant period you work full-time overseas, have no significant break from overseas work, do not work more than 3 hours in the UK on more than the permitted number of days, and spend no more than the permitted number of days in the UK.

Permitted limits (RFIG21220) - here the date is the date the relevant period ends:

The sufficient hours overseas calculation (RFIG20150) is applied to the relevant period rather than the whole year, and the cap on days subtracted for gaps between employments drops from 30 days to the permitted limit (X) above.

When does the UK part start? The overseas part runs from the start of the tax year to the last day of the latest period for which you satisfy the sufficient hours test, tested from the start of the year to that day (RFIG21230).

The HMRC example (RFIG21230): Edward left the UK on 1 November 2010 to work full-time in Switzerland, having always lived and worked in the UK before that. He kept a UK apartment throughout. He retires with a last overseas workday of 31 October 2014 and returns permanently to the UK on 3 November 2014.

He qualifies for Case 6 for 2014–15: he was non-resident in 2013–14 through full-time work overseas, he worked full-time overseas from 6 April to 31 October 2014, he was UK resident in at least one of the four years before 2013–14, and he is UK resident in 2015–16. His overseas part ends 31 October 2014 and his UK part starts 1 November 2014 - two days before he physically returned.

Case 7: Partner of someone ceasing full-time work overseas

Case 7 mirrors Case 2. If you were living abroad with a partner who qualifies for Case 6, and you follow them back to the UK, you may qualify even though you do not meet the work conditions yourself.

Conditions (RFIG21240):

• You are UK resident for the tax year and were non-UK resident for the previous tax year
• Your partner's circumstances fall within Case 6, either this tax year or the previous one
• You move to the UK during the tax year so you can continue living together with your partner
• You are UK resident in the following tax year
• In the part of the year before your deemed arrival day, you either had no UK home at any time, or - if you had homes in both countries - you spent the greater part of your time living in the overseas home
• You do not exceed the permitted limit of UK days (column Y in the Case 6 table above) in the overseas part, taking the date as the day before your deemed arrival day

Deemed arrival day (RFIG21250): the later of

• the first day of the UK part of the year for your partner under Case 6, and
• the day you move to the UK to live together

When does the UK part start? On the deemed arrival day; the overseas part runs from the start of the tax year up to it (RFIG21260).

The HMRC example (RFIG21260): Joan is Edward's wife and lived with him in Switzerland. She retires too, but works her notice at her part-time job and arrives in the UK on 8 November 2014, five days after Edward. She does not qualify for Case 6 herself - her part-time hours do not meet the third automatic overseas test - and she does not qualify for Cases 4, 5 or 8 either. Her deemed arrival day is the later of Edward's Case 6 split date (1 November) and her own arrival (8 November), so her UK part starts 8 November 2014.

Case 8: Starting to have a UK home

Case 8 covers arriving and acquiring a UK home while keeping an overseas home - the distinction from Case 4.

Conditions (RFIG21270):

• You are UK resident in the tax year and were non-UK resident for the previous tax year
• You are UK resident for the following tax year, and that year must not itself be a split year
• You had no UK home at the beginning of the tax year, start to have one at some point during it, and continue to have a UK home for the rest of that year and all of the following tax year
• You do not have sufficient UK ties between 6 April and the point you start to have a UK home, applying the reduced limits in the table above

The two-year commitment is the trap here. Case 8 requires the UK home to persist through the whole of the next tax year as well, and that next year must be a full year of UK residence rather than another split year.

When does the UK part start? On the date you start to have a UK home (RFIG21280).

The HMRC example (RFIG21280): Nicola is retired and non-resident, having lived in Cyprus for several years. She owns a UK property that has been commercially let. She decides to split her time between the two countries to see her new grandson, and moves into the UK property when the tenancy expires on 4 August 2014. She now has two homes, one in each country. Between 6 April and 4 August she spent only 4 days in the UK.

She qualifies for Case 8 for 2014–15: non-resident in 2013–14, UK resident in 2015–16, a UK home continuing through the rest of 2014–15 and all of 2015–16, and insufficient UK ties before 4 August. Her UK part starts 4 August 2014. Note the timing point: a property let out commercially is not your home for the period it is let, unless you or your family retain a right to live there (RFIG22150). Nicola had owned the UK property for years, but it only became her home when the tenancy ended and she moved in.

Case 4 or Case 8?

These two are the most commonly confused, and they hinge on a single question: did you keep a home overseas?

If you moved to the UK and sold or gave up the overseas property, look at Case 4. If you kept it, look at Case 8.

Working out which of the 8 cases applies - and which wins when several do - is the part people get wrong. The Split Year Treatment Dashboard takes your dates and circumstances, applies the priority rules, and returns the case and your exact split date, showing which conditions you meet and which you miss. If you already have premium access, open the dashboard directly.

What this means in practice

For a full walkthrough of the steps to take before and after leaving - including how to count UK days, which ties to watch, and the most common mistakes - see the leaving the UK tax residency guide.

If you left or arrived in the UK part-way through a tax year and were UK resident for that year, you need to:

1. Work through each of the 8 cases to determine whether any apply to you
2. Identify your split year date
3. Report split year treatment on your Self Assessment tax return - box 3 of the SA109 residence pages, with your split date in box 6 (SA109 explained box by box)
4. Keep records of the dates you were present in each country and any work done in the UK during the overseas part

If you are unsure whether leaving the UK means filing a P85 or the SA109 residence pages, the P85 or SA109 helper works it out from a few questions.

The Split Year Treatment Dashboard automates this process: enter your circumstances and it determines which case applies, calculates your split date, and shows which conditions you meet or miss. If you already have premium access, open the dashboard directly.

Because split year treatment interacts with the automatic overseas tests, the sufficient ties test, and double taxation treaty positions, it can become complex quickly. Start by confirming whether you are UK resident for the year - the free SRT calculator will run you through the full test - and then consider professional advice on the split year question.