Split Year Treatment: What It Is and When It Applies
Split year treatment divides a UK tax year into a UK part and an overseas part when you leave or arrive mid-year. Learn the 8 cases, the conditions for each, and a worked example.
If you leave the UK part-way through a tax year, the Statutory Residence Test will typically still classify you as UK resident for that entire year. Split year treatment fixes this: it divides the year into a UK part and an overseas part, so that you are only taxed as a UK resident up to the point you leave. If you meet the conditions, 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:
| Case | Scenario |
|---|---|
| Case 1 | You start full-time work overseas |
| Case 2 | You are the partner of someone who qualifies for Case 1 |
| Case 3 | You cease to have a UK home |
Arriver cases - you were non-resident and come to the UK mid-year:
| Case | Scenario |
|---|---|
| Case 4 | You start to have a UK home only (no overseas home) |
| Case 5 | You start full-time work in the UK |
| Case 6 | You cease full-time work overseas |
| Case 7 | You are the partner of someone who qualifies for Case 6 |
| Case 8 | You start to have a UK home (which may include an overseas home) |
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:
| Relevant period starts | Permitted UK work days (X) | Permitted UK days (Y) |
|---|---|---|
| 6–30 April | 30 | 90 |
| 1–31 May | 27 | 82 |
| 1–30 June | 25 | 75 |
| 1–31 July | 22 | 67 |
| 1–31 August | 20 | 60 |
| 1–30 September | 17 | 52 |
| 1–31 October | 15 | 45 |
| 1–30 November | 12 | 37 |
| 1–31 December | 10 | 30 |
| 1–31 January | 7 | 22 |
| 1–29 February | 5 | 15 |
| 1–31 March | 2 | 7 |
| 1–5 April | 0 | 0 |
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 leaver case, priority rules determine which case applies and what date the year splits from (RFIG21030):
Case 1 > Case 2 > Case 3
Case 1 takes priority over both Case 2 and Case 3. Case 2 takes priority over Case 3.
Cases 4–8: arriving in the UK
If you are coming to the UK mid-year from abroad, the relevant cases are 4–8. These mirror the leaver cases in structure: you are classified as UK resident for the year as a whole, but the UK part runs only from your arrival trigger date. Case 5 (starting full-time UK work) and Case 8 (starting to have a UK home) are the most common for people relocating to the UK for work.
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:
- Work through each of the 8 cases to determine whether any apply to you
- Identify your split year date
- Report split year treatment on your Self Assessment tax return
- Keep records of the dates you were present in each country and any work done in the UK during the overseas part
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 calculator below will run you through the full SRT - and then consider professional advice on the split year question.
Work out your UK residence status
Our free calculator follows HMRC's RDR3 guidance step by step - automatic overseas tests, automatic UK tests, and the sufficient ties test - and gives you a clear determination with full reasoning you can take to your tax adviser.
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