Split-year treatment: the eight cases, and which one is yours

The Statutory Residence Test gives a binary answer: for a tax year you are either UK resident or you are not, and that status applies to every day of the year. Which is a problem if you left in October, because it means a full year of UK residence sitting over six months you spent in Dubai.

Split-year treatment is the exception. It divides the tax year into a UK part and an overseas part, and for most purposes you are charged to UK tax as a non-resident for the overseas part. It is worth serious money to anyone moving in either direction mid-year.

Two things about it surprise almost everybody. It is not optional — HMRC's guidance is explicit that where the conditions are met, split-year treatment applies whether you want it or not. And it is not a general fairness rule: you either fit one of eight specific statutory cases or the year does not split at all, however obviously your life changed in the middle of it.

The eight cases

Three cases cover leaving the UK and five cover arriving. Each has its own detailed conditions, all of which must be met, and each sets its own date for the split. These are HMRC's own case titles.

Case	Situation	Direction
Case 1	Starting full-time work overseas	Leaving
Case 2	The partner of someone starting full-time work overseas	Leaving
Case 3	Ceasing to have a home in the UK	Leaving
Case 4	Starting to have a home in the UK only	Arriving
Case 5	Starting full-time work in the UK	Arriving
Case 6	Ceasing full-time work overseas	Arriving
Case 7	The partner of someone ceasing full-time work overseas	Arriving
Case 8	Starting to have a home in the UK	Arriving

Where more than one case applies — and that happens often, because someone starting a job abroad usually also gives up a UK home — HMRC's priority ordering rules decide which case governs, and therefore which date the year splits on. The split dates under different cases can be weeks or months apart, which is why the ordering is not a technicality. HMRC sets out the rules and the conditions for each case in its Residence and FIG Regime Manual.

The precondition everyone forgets

Split-year treatment only exists inside a year in which you are UK resident under the Statutory Residence Test. If the test says you are non-resident for the year, there is nothing to split — you are simply non-resident throughout, which is usually the better answer anyway.

So the order of work is always the same. Run the residence test for the year first. Only if it comes back “resident” do you go looking for a split-year case. Doing it the other way round — assuming a split and then working backwards — is how people end up filing a return that does not match their day count. Our guide to the Statutory Residence Test covers the first half of that job, and the split-year treatment checker the second.

What the split actually changes

In the overseas part you are taxed as a non-resident. In practice that means:

Employment income for duties performed abroad in the overseas part falls out of the UK charge.
Foreign income and gains arising in the overseas part are outside UK tax.
UK-source income continues to be taxable throughout, both parts — UK rental profit above all. Leaving the country does not remove UK property from the UK tax net, which is what the Non-resident Landlord Scheme exists to police.
Disposals of UK land and property remain reportable and taxable whichever part of the year they fall in, on the 60-day timetable. See our guide to the 60-day CGT rule.
Your personal allowance is not apportioned. A split year does not halve it. This is one of the few places where the rules are more generous than people expect.

Social security is a separate question with its own rules and reciprocal agreements — your National Insurance position does not follow the split-year date automatically, and if you are planning to keep a UK record while abroad, that is handled through voluntary contributions from abroad.

How this typically plays out

An illustrative case, using the published 2026/27 rates. A UK employee leaves on 30 September 2026 to start a full-time job in Dubai, gives up the UK home, and meets the Case 1 conditions.

UK employment, 6 April to 30 September 2026: £48,000.
Dubai employment, 1 October 2026 to 5 April 2027: £52,000, with no local income tax.

	Split year applies	No case met
UK taxable employment income	£48,000	£100,000
Less personal allowance	(£12,570)	(£12,570)
Taxable	£35,430	£87,430
Basic rate, £37,700 at 20%	£7,086	£7,540
Higher rate at 40%	—	£19,892
UK income tax	£7,086	£27,432

A difference of £20,346 on identical facts, decided entirely by whether the conditions of one statutory case were met and evidenced. There is no foreign tax credit to soften the second column, because the UAE charges no personal income tax on that salary — a point that catches people moving to the Gulf far more often than those moving to higher-tax countries.

Note also what would have happened to a bonus. A bonus for UK duties, paid in November after the split date, is still UK employment income for UK duties: the payment date does not move it into the overseas part. Relocation timing around a bonus is one of the few genuinely valuable planning conversations available to a leaver, and it has to happen before the move.

The five-year tail

Getting the split right in the leaving year is not the end of it. If you were UK resident for at least four of the seven tax years before you left, and you come back within roughly five years, the temporary non-residence rules can pull gains and certain income realised while you were away back into charge in your year of return.

That matters most to owner-directors: distributions from close companies taken during a short period abroad are squarely within those rules. Selling a company or clearing a reserve while non-resident, then returning inside five years, is the classic way a well-executed departure produces a large and unexpected bill later. HMRC's helpsheet HS278 covers the capital gains side.

What to do about it

Fix the date, in writing, before you go. Contract start date abroad, the day the UK home stopped being available, flight records. The split date is an evidenced fact, not a preference.
Run the residence test for the whole year first. If you are non-resident anyway, split-year is irrelevant.
Work out which cases you might meet, then apply the priority order. Two cases with two different dates is normal, and the ordering rules decide.
Keep the day count for the rest of the year. Most leaving cases carry limits on UK days after departure, and a Christmas visit home can be the thing that breaks a case worth five figures.
Tell HMRC properly. The split-year position goes on the residence pages of the Self Assessment return, with the case number stated. It is not something an employer's payroll can do for you.

If you are planning a move in either direction, our pages on leaving the UK and moving to the UK set out the wider sequence, and the UK day count checker is the tool to keep running once you have gone.

Rates used above are the published figures for 2026/27: personal allowance £12,570 and a basic rate limit of £37,700. Correct at 7 September 2026.

Questions readers ask

Can I choose whether split-year treatment applies?

No. HMRC's guidance is explicit that split-year treatment applies automatically where the conditions of a case are met — it is not an election and there is no box to opt out of it. That cuts both ways. Someone who would prefer to remain UK resident for the whole year, perhaps to keep a relief that depends on residence, cannot simply decline the split. And someone who wants the split cannot have it by asserting that their life obviously changed in October. The only question is factual: do you meet every condition of one of the eight cases, and can you evidence it?

What happens if two split-year cases apply to me?

That is common rather than exceptional, because someone who starts full-time work abroad has usually also given up their UK home. HMRC's priority ordering rules decide which case governs, and the case that governs sets the date on which the year splits. Those dates can be materially different — the day you started the overseas job and the day the UK home ceased to be available may be months apart — and a bonus, a share disposal or a final salary payment falling between them lands on one side or the other. Work out every case you meet before deciding your split date, not just the first one that fits.

Does split-year treatment stop HMRC taxing my UK rental income?

No, and this is the most common misunderstanding. UK-source income remains taxable in both parts of a split year, and UK property income is UK-source wherever you live. What changes is the administration: from the point you are treated as non-resident, your letting agent or tenant comes within the Non-resident Landlord Scheme and must deduct basic-rate tax from the rent unless you have been approved to receive it gross. Disposals of UK land are likewise reportable within 60 days regardless of which part of the year they fall in. Split-year treatment is about foreign income, not UK income.

Do I still get the full personal allowance in a split year?

Yes. The personal allowance is not apportioned between the UK part and the overseas part, so a leaver with six months of UK employment income sets the full £12,570 against it rather than half. That is genuinely generous and it is why a mid-year departure often produces a repayment through the return, since PAYE will have been deducting on the assumption of a full year's salary. Entitlement to the allowance in later years is a separate question — as a non-resident it depends on nationality or a treaty, and it is not automatic for everyone.