Key points
- Your UK tax residence is decided by the statutory residence test, tax year by tax year, so the date you arrive can matter more than the date you decide to return.
- In a year of arrival you may qualify for split year treatment, which can keep part of the year outside UK tax on foreign income and gains.
- The new four year foreign income and gains regime requires ten consecutive tax years of non residence beforehand. Most returning expats will not qualify.
- If you return within five years of leaving, the temporary non residence rules can tax gains and some income you received while abroad.
- Your history of UK residence can put your worldwide assets inside UK inheritance tax again very quickly after you return.
- Several decisions are cheaper to make before you land: selling assets, pension withdrawals, closing foreign accounts and filling State Pension gaps.
Most expats plan their departure carefully and their return hardly at all. The return matters just as much. Becoming UK resident again changes how your income, gains, pensions and estate are taxed, and a few of the best options are only available if you act before you arrive. This guide follows the order in which the questions come up.
Residence on the way back: the test and the arrival date
UK tax residence is decided for each tax year (6 April to 5 April) under the statutory residence test (SRT). You are resident for a year if you meet one of the automatic UK tests, or if you do not meet an automatic overseas test and satisfy the sufficient ties test.
- Automatic UK tests. You are resident if you spend 183 days or more in the UK in the year; or you have a UK home and meet the home conditions (broadly, a period of 91 consecutive days with that home, at least 30 of them in the year, and little or no use of an overseas home); or you work full time in the UK over a 365 day period.
- Automatic overseas tests. You are not resident if you were UK resident in at least one of the previous three tax years and spend fewer than 16 days in the UK, or you were not resident in any of those three years and spend fewer than 46 days in the UK. A third test covers full time work overseas with fewer than 91 days in the UK and fewer than 31 days in which you work in the UK for more than three hours.
- Sufficient ties. The remaining cases depend on how many days you spend in the UK and how many ties you have: family, accommodation, work, the 90 day tie and, if you were UK resident in one of the three previous years, a country tie. Someone who has been away for longer than three years faces a stricter table than someone who left recently, with more ties needed at each band of days.
A day normally counts if you are in the UK at midnight at the end of it. Residence follows the whole tax year, which is why returning in mid year does not mean the whole year is taxed in the same way.
Split year treatment
If you become resident part way through a year, split year treatment can divide the year into an overseas part and a UK part. Cases 4 to 8 of the SRT apply to people arriving in the UK. In summary:
- Case 4: starting to have a home in the UK only, where you did not have a UK home at the start of the year.
- Case 5: starting full time work in the UK.
- Case 6: ceasing full time work overseas.
- Case 7: the partner of someone who ceases full time work overseas.
- Case 8: starting to have a home in the UK.
Each has strict conditions, including that you were not UK resident in the previous year and that you meet the test on a reduced day count for the part of the year before the relevant event. You cannot choose split year treatment. If the conditions are met it applies, and if they are not, you are resident for the whole year.
Worked example (illustrative). Someone who was non resident in 2025/26 buys a UK home and moves in on 1 November 2026. Assume they meet Case 8 and are resident in 2027/28.
- Foreign dividends received between 6 April and 31 October 2026 total £9,000. Those fall in the overseas part of the year and are generally outside UK tax.
- Foreign dividends received from 1 November 2026 to 5 April 2027 total £7,000. Those fall in the UK part, so they are taxable in the UK unless a relief applies.
If they had arrived on 10 April 2027 instead, the whole of 2026/27 would sit outside residence (assuming they stayed under the day limits), and the UK part would begin in 2027/28. The choice of arrival date can move income from one tax year to another. It rarely removes tax, but it can change when and how much, and it is far easier to plan before travel than after.
Foreign income and gains after April 2025
From 6 April 2025, the old non domicile system was replaced by a residence based regime. Two things matter for returners.
- The default. Once you are UK resident, you are taxed on your worldwide income and gains as they arise. Foreign tax credits can reduce double taxation, and a double tax treaty may allocate taxing rights. The remittance basis no longer exists for new claims.
- The four year foreign income and gains (FIG) regime. A qualifying new resident can claim relief on foreign income and gains for up to four tax years, without bringing the money to the UK. To qualify, you must be UK resident for the year and have been non resident for the ten consecutive tax years immediately before it. HMRC says residence is judged under the SRT from 2013/14, and a split year in the past counts as a year of residence. Nationality and domicile do not matter.
That ten year requirement is the point most people miss. Someone who was away for six or eight years will normally not qualify, even if they had a long career abroad. A claim also has costs: for a tax year in which you claim relief on foreign income or gains, you lose your personal allowance and the capital gains annual exempt amount for that year, and the choice is made year by year. The same applies to elections for overseas workday relief, which can help employees with duties performed outside the UK and is capped at the lower of 30% of qualifying earnings and £300,000.
Temporary non residence: the five year trap
If you left the UK and return within five years, special rules can bring some gains and income into the charge in the year you come back. The conditions are that you were UK resident for all or part of at least four of the seven tax years before you left, and that your period of non residence totals no more than five years.
- Gains. Gains on assets you owned before you left and sold while abroad are treated as arising in the year you return. Assets bought after you left are generally outside the rule, apart from some linked cases.
- Income. Certain income received while abroad can also be taxed in the return year, including some pension lump sums and flexible drawdown withdrawals, particular company payments and gains on some insurance policies.
- Employment income is excluded.
Worked example (illustrative). You left the UK in 2023 and return in 2026/27, and you meet the condition of being resident in at least four of the seven tax years before leaving. In 2025/26 you sold shares you had owned since before leaving, with a gain of £40,000.
- Because you return within five years, assume the gain is treated as arising in 2026/27.
- Assume your other income puts you in the higher rate band, so the gain is taxed at 24%, with the £3,000 annual exempt amount available.
- Tax is roughly (£40,000 less £3,000) at 24%, which is £8,880.
Foreign tax paid on the same gain may be relieved under a treaty. The point is that selling while non resident does not necessarily avoid UK tax if you come back soon. Understand this before you sell, not after. If the five years are close, the timing of your return may be worth discussing with a tax adviser.
Pensions, investments and overseas property
Pensions
- UK pensions are taxed as income when drawn, as for any UK resident. Tax free cash rules (25% up to the lump sum allowance of £268,275) continue to apply.
- Overseas pensions and schemes that you built abroad may be taxed differently once you are resident. Do not assume a tax free lump sum that was available abroad will be tax free in the UK.
- Contributions. Once you are resident, you can usually get tax relief on contributions up to your UK earnings, subject to the annual allowance (£60,000 for 2026/27 before any taper).
- Drawing before you arrive. The tax position on lump sums taken while non resident can differ from taking them afterwards. If you plan a withdrawal, take advice before the date you become resident, not after.
Investments and tax wrappers
- Taxable investments. UK tax applies to income and gains from arrival. For 2026/27 the capital gains rates are 18% and 24%, with a £3,000 annual exempt amount. Dividend rates are 10.75%, 35.75% and 39.35%, with a £500 allowance.
- Offshore tax wrappers. Offshore investment bonds commonly used by expats are generally taxed on a UK resident as a form of income when a chargeable event occurs. Check the rules for your wrapper before you arrive and consider whether surrendering before the date you become resident is appropriate.
- ISAs. Check the rules for holding and subscribing to ISAs on return, and whether your existing accounts retained their status while you were away.
- Cost basis. Records of what you paid, and when, become important again. Keep them from the day you land.
Overseas property
Rental income from property abroad becomes taxable in the UK, with a credit for tax paid in the country where it sits. A sale of a foreign property after you become resident is within UK capital gains tax, again with credit for foreign tax. If you are keen to sell, think about whether to do so before you arrive, subject to the temporary non residence rules above. If you keep it, consider how a foreign mortgage is treated, since UK relief for interest on overseas property is limited.
Inheritance tax, State Pension and National Insurance
Inheritance tax
Since 6 April 2025 UK inheritance tax on assets outside the UK depends on long term UK residence. You are a long term resident for an event if you were UK resident for at least 10 of the 20 tax years before the tax year of the event, and a split year counts as a full year. After you leave, you stay in scope for between three and ten years depending on how long you were resident. So returning does not start a new ten year clock, because your earlier years of residence still count within the 20 year window.
Worked example (illustrative). Someone was UK resident for 13 tax years until 2017/18, lived abroad from 2018/19 to 2025/26 and returns in 2026/27.
- For an event in 2026/27, the 20 year look back runs from 2006/07 to 2025/26. They have 12 years of residence in that window, so they are a long term resident immediately.
The rates are 40% over the nil rate band of £325,000, with the residence nil rate band of up to £175,000 and both currently frozen until April 2031. From 6 April 2027 most unused pension funds are due to count towards an estate. Review wills in each country where you hold assets, and consider whether gifts, trusts or life cover written in trust are needed.
State Pension and National Insurance
- A full new State Pension is £241.30 a week for 2026/27 and needs 35 qualifying years. At least 10 are needed to get anything.
- If your State Pension was paid abroad in a country without yearly increases, it goes up to the current rate when you come back to live in the UK.
- Check your forecast on GOV.UK. Gaps can often be filled with voluntary contributions for up to six years back. For 2026/27 Class 3 is £18.40 a week.
- For time abroad after 5 April 2026, voluntary Class 2 is no longer available, and Class 3 requires 10 years of UK residence or contributions. If you are still abroad, check this before you return.
A practical timeline
- Twelve to six months before. Count likely UK days. Decide the arrival date. List assets, pensions, bonds and foreign accounts. Check whether the temporary non residence rules apply. Review the State Pension forecast.
- Six to three months before. Take advice on timing for withdrawals, disposals and tax wrapper surrenders. Check whether split year treatment is likely. Update wills. Ask UK pension providers about your address and bank details.
- Three months to arrival. Tell your banks and pension providers you are returning. Arrange UK proof of address and credit history. Close or notify overseas tax authorities as required. Keep travel and day count records.
- First month in the UK. Register with a GP, check your National Insurance number, update HMRC if you have taxable income, and set up UK bank and savings accounts. Keep your move date evidence.
- First tax year. Register for Self Assessment if needed, using the residence pages (SA109) to show split year or FIG relief. Diarise 5 October and 31 January.
Common mistakes
- Assuming the four year FIG regime applies without checking ten years of non residence.
- Selling assets abroad just before returning without checking the temporary non residence rules.
- Choosing an arrival date for convenience, not for the tax year it falls in.
- Forgetting to claim, or wrongly claiming, FIG relief, which carries a loss of allowances.
- Leaving pension or investment plans in structures that are costly to hold as a UK resident.
- Assuming inheritance tax exposure starts fresh on return.
- Not keeping a day count and evidence file from the start.
Questions to ask a tax adviser
- Based on my days and ties, which tax year am I likely to be resident, and does a split year apply?
- Do I qualify for the four year FIG regime, and would it be worth the allowances I lose?
- Do the temporary non residence rules apply to me, and what is the exposure?
- How will each of my pensions, bonds and accounts be taxed after I arrive?
- What does my UK residence history mean for inheritance tax, and should I change my will or ownership?
- Should I fill State Pension gaps, and by when?
What to do next
- Write down your planned arrival date and the number of UK days you expect before it.
- List every asset, pension and account with a note of where each is taxed.
- Check the date you left the UK and whether you are inside five years.
- Get your State Pension forecast and voluntary contribution options.
- Speak to a regulated adviser and a qualified tax adviser before you finalise dates.
Sources and checks
- GOV.UK, Tax if you return to the UK
- GOV.UK, Tax on foreign income: residence
- HMRC guidance note for the statutory residence test (RDR3)
- HMRC Residence and FIG Regime Manual, split year treatment (RFIG21000)
- HMRC Residence and FIG Regime Manual, qualifying new resident (RFIG44000)
- HMRC Residence and FIG Regime Manual, effects of a claim (RFIG43000)
- HMRC, Temporary non residents and Capital Gains Tax (HS278)
- HMRC Inheritance Tax Manual, long term UK residence (IHTM47020)
- GOV.UK, Voluntary National Insurance contributions if you live or work abroad
- GOV.UK, Capital Gains Tax rates and allowances
- GOV.UK, Income Tax rates and allowances 2026/27
- To double check before relying on it: the detailed conditions for the sufficient ties test and split year cases on your own facts, the tax treatment of offshore bonds and overseas pensions on arrival, NHS access, ISA subscription rules on return, and any State Pension changes.