International Tax UK 2026/27 — Moving Abroad, Expats, Non-Doms and Digital Nomads

Whether you are moving to the UK, leaving it, working remotely across borders, or managing income from multiple countries, UK international tax rules can be surprisingly complex. Your liability depends primarily on your tax residency status under the Statutory Residence Test — not where you hold a passport, where your employer is based, or where your bank account sits.

The rules have also changed significantly in recent years. The non-domicile remittance basis was abolished from April 2025, replaced by a four-year Foreign Income and Gains exemption for new arrivals. Anyone who structured their finances around the old non-dom regime needs to understand the new rules urgently.

This hub covers the key international tax scenarios for UK taxpayers in 2026/27: the residency test, split year treatment, the FIG exemption, leaving and arriving in the UK, digital nomads, and double taxation treaties.

UK Tax Residency — The Statutory Residence Test

Every international tax question starts with: are you UK tax resident?

The Statutory Residence Test (SRT), set out in HMRC’s RDR3 guidance, uses a series of automatic tests and a sufficient ties test based on days spent in the UK and personal connections.

Automatic Overseas Tests (automatically non-resident if ANY apply)

• You spent fewer than 16 days in the UK in the tax year (if UK resident in 1 or more of the previous 3 tax years)
• You spent fewer than 46 days in the UK (if non-resident in all of the previous 3 tax years)
• You work full-time overseas (35 hours/week average) with fewer than 91 days in the UK and fewer than 31 working days in the UK

Automatic UK Tests (automatically UK resident if ANY apply)

• You spent 183 or more days in the UK in the tax year
• Your only home was in the UK for at least 91 consecutive days (and you were there for at least 30 days in the tax year)
• You worked full-time in the UK for any 365-day period

The Sufficient Ties Test

If neither automatic test applies, residency depends on your number of UK ties and days spent in the UK:

UK ties include: a UK home, substantive UK work (more than 40 days at 3+ hours/day), a UK-resident close family member (spouse, civil partner, or minor child), spending more than 90 days in the UK in either of the previous two tax years, and spending more time in the UK than in any other single country.

The SRT is applied year by year. You can be UK resident in one year and non-resident the next. Keeping a day count and documenting your ties is essential if you are close to a threshold.

Split Year Treatment

In the year you arrive in or leave the UK, you will often have a period of UK residence and a period of non-residence in the same tax year. HMRC’s split year rules divide that year into a UK part and an overseas part:

• UK part: Income and gains taxed under normal UK rules
• Overseas part: Only UK-sourced income remains taxable (not foreign income)

There are eight different split year cases, covering different combinations of when you arrive or leave and whether you have overseas or UK employment. The rules are detailed — if your departure or arrival is mid-year and you have significant foreign income, professional tax advice is worth the cost.

UK Income That Stays Taxable Even When Non-Resident

Becoming non-UK resident does not eliminate all UK tax. The following remain taxable in the UK regardless of where you live:

• UK rental income — taxed under the Non-Resident Landlord scheme; your letting agent or tenant deducts basic-rate tax at source unless HMRC grants approval to receive rent gross
• UK pensions — most UK pension income remains taxable in the UK, though double taxation treaties can shift taxing rights to your country of residence
• UK employment income — earnings for work physically performed in the UK are taxable in the UK, even if you are non-resident
• UK savings interest — bank interest from UK accounts is generally taxable in the UK (though the starting rate for savings and Personal Savings Allowance may reduce or eliminate the liability)
• UK capital gains — non-residents are liable for Capital Gains Tax on disposals of UK residential property and, since April 2019, commercial property and indirect interests in UK property

The FIG Exemption — What Replaced Non-Dom Status

From 6 April 2025, the non-domicile remittance basis was replaced by the Foreign Income and Gains (FIG) exemption:

Who qualifies: Individuals who were non-UK resident for the 10 consecutive tax years immediately before their first year of UK residence.

What it covers: All foreign income and gains — dividends, interest, rental income from overseas property, overseas capital gains — are exempt from UK tax for the first four tax years of UK residence, regardless of whether the money is brought to the UK.

After four years: Worldwide income and gains become taxable on the arising basis (the same as any long-term UK resident).

Transitional rules: Existing non-doms who had been using the remittance basis were offered transitional arrangements when the rules changed in 2025 — including a one-off opportunity to rebase foreign assets and a Temporary Repatriation Facility to bring overseas income to the UK at reduced rates. The window for these transitional reliefs is now largely closed.

Anyone previously structured as a non-dom who did not engage with the transitional rules should take advice urgently — their overseas income is now taxable in full.

Key Steps When Leaving the UK

1. Determine your departure date for SRT purposes and count UK days carefully from that date onwards
2. Submit form P85 to HMRC after leaving — this updates your tax code and triggers a review of any tax owed or refundable for the year of departure
3. Consider whether Self Assessment is required for the year of departure — if you have foreign income or significant UK income after leaving, a return is likely needed
4. Set up the Non-Resident Landlord scheme if you are keeping UK property to rent — prevents your tenant or agent being required to deduct tax at source
5. Review pension nominations — your nomination of beneficiaries may have different tax implications for non-residents, particularly from April 2027 when pensions become subject to IHT
6. Keep day-count records — HMRC can enquire into residency years after the event; diary evidence of days outside the UK is essential

Key Steps When Arriving in the UK

1. Register with HMRC — if you have income outside PAYE, register for Self Assessment and obtain a National Insurance number
2. Determine your start date and check whether split-year treatment applies — this can save significant tax on foreign income earned before you arrived
3. Check FIG eligibility — if you have been non-UK resident for 10 years, your foreign income may be exempt from UK tax for four years
4. Open a UK bank account — most require proof of address and identity; some challenger banks are more flexible for new arrivals
5. Check your home country tax obligations — many countries tax residents on worldwide income regardless of where they live; you may need to file in both the UK and your home country (double taxation treaties usually prevent double payment)

Guides in This Cluster

• Digital Nomad Tax UK — How Remote Workers Are Taxed — SRT implications, setting up overseas, and HMRC compliance for location-independent workers
• UK Double Taxation Treaties — How They Work — which countries have treaties with the UK and how to claim relief
• Leaving the UK — Tax Guide — P85, split year, and what to do before and after departure
• Moving to the UK — Finance Guide — banking, credit history, NI numbers, and practical money setup for new arrivals
• Moving to the UK — Tax Guide — SRT, FIG exemption, and HMRC registration for new UK residents
• Non-Domicile Tax Status Changes UK — what the abolition of non-dom status means and the FIG exemption in detail

Related Hubs

• Income Tax Hub — UK rates and allowances for residents
• Self Assessment Hub — filing returns and HMRC dealings for complex tax situations
• Capital Gains Tax Hub — CGT on UK property for non-residents
• Inheritance Tax Hub — IHT implications for non-domiciles and non-residents