21/10/2026
🇬🇧 UK TAX RESIDENCY – WHY THE RULES MATTER MORE THAN EVER
📢 Major changes to the UK taxation of foreign income and gains came into effect on 6 April 2025.
Previously, eligible UK residents who were non-UK domiciled could claim the remittance basis of taxation, meaning that certain foreign income and capital gains were generally only taxed in the UK when brought into or used in the UK.
For example, foreign investment income retained in an overseas bank account could remain outside the UK tax charge under the remittance basis.
What has changed?
From 6 April 2025, the remittance basis was abolished and replaced by a residence-based system.
✅ 4-year Foreign Income and Gains (FIG) regime – Qualifying individuals who become UK tax resident after at least 10 consecutive tax years of non-UK residence may claim relief on eligible foreign income and gains during their first four years of UK tax residence.
✅ Worldwide taxation – UK tax residents who do not qualify for FIG relief are generally subject to UK income tax and capital gains tax on their worldwide income and gains, subject to applicable exemptions and double taxation agreements.
✅ Inheritance Tax (IHT) – The new long-term residence rules generally bring worldwide assets within the scope of UK IHT once an individual has been UK tax resident for at least 10 of the previous 20 tax years. Exposure can also continue after leaving the UK.
⚠️ Does this mean individuals with international connections should avoid becoming UK tax resident?
Not necessarily.
UK tax residency is determined under the Statutory Residence Test (SRT), which considers several factors, including:
* Number of days spent in the UK.
* Family connections, including spouses and minor children.
* Availability of accommodation in the UK.
* Employment and working days in the UK.
* Previous UK residence and other relevant UK ties.
Importantly, spending fewer than 183 days in the UK does not automatically mean you are non-UK tax resident.
Even relatively short visits may affect your residency position depending on your circumstances.
👨👩👧 Did you know?
Under the SRT, having a minor child resident in the UK can create a UK family tie. However, specific exceptions apply, including where the individual sees that child in person in the UK on fewer than 61 days during the tax year.
Why is careful tax planning essential?
For individuals living between the UK and another country, understanding tax residency, double taxation treaties and the number of days spent in each jurisdiction is increasingly important.
Being tax resident in another country does not automatically prevent you from also being UK tax resident under domestic rules.
A properly documented residency position can make a significant difference if HMRC opens an enquiry several years later.