Leaving the UK is refreshingly rule-based. Where Germany argues about flats and Spain about your “centre of interests”, the UK hands you a statute with day counts, tables and flowcharts. The flip side: HMRC expects you to know them, and it counts midnights.
This guide explains how UK tax residence ends, which traps survive your departure (hello, temporary non-residence and the new inheritance tax tail), what stays taxable and a practical 12-month plan. General information as of September 2026, not tax advice.
Who this guide is for#
You live in the UK and plan to move abroad for a few years or for good. Maybe you’re a founder heading to Cyprus or Dubai, a remote employee moving to Portugal, or a former non-dom wondering what the 2025 reforms mean on the way out.
Own a company, UK property or a pension pot? Read this before you book the flight. The UK tax year runs from 6 April to 5 April, and everything below is measured in those years.
How residence ends: the Statutory Residence Test#
Since April 2013 the Statutory Residence Test (SRT) in Schedule 45 of the Finance Act 2013 decides whether you’re UK resident for a tax year. You work through it in order: automatic overseas tests, automatic UK tests, then the sufficient ties test. A “day” generally counts if you’re in the UK at midnight.
Automatic overseas tests: the clean exit#
You’re automatically non-resident for the tax year if any of these applies:
| Test | Condition |
|---|---|
| First | You were UK resident in one or more of the previous 3 tax years and spend fewer than 16 days in the UK |
| Second | You were UK resident in none of the previous 3 tax years and spend fewer than 46 days in the UK |
| Third | You work full-time overseas, spend fewer than 91 days in the UK and work more than 3 hours on fewer than 31 of them, without a significant break from your overseas work |
As a leaver, test one is the relevant one – and 15 days a year is not a lot of Christmas. The full-time work test is the friendlier route for employees and genuinely busy founders abroad.
Automatic UK tests: the ways to stay resident by accident#
You’re automatically resident with 183 or more UK days, with full-time UK work over a 365-day period, or under the home test: a UK home for at least 91 consecutive days (30 of them in the tax year) where you spend at least 30 days, while you have no overseas home or spend fewer than 30 days in it. Keeping the London flat while your new place abroad is still an Airbnb is how the home test bites.
Sufficient ties: days vs ties#
If no automatic test decides it, the number of UK ties sets how many days you can spend. For leavers (resident in at least one of the previous 3 years) the table is stricter than for arrivals:
| Days in the UK | Leaver: resident with | Arriver: resident with |
|---|---|---|
| 16–45 | 4 ties or more | Always non-resident |
| 46–90 | 3 ties or more | 4 ties |
| 91–120 | 2 ties or more | 3 ties or more |
| More than 120 | 1 tie or more | 2 ties or more |
The ties:
- Family tie. Your spouse, civil partner or partner, or a child under 18, is UK resident.
- Accommodation tie. Accommodation is available to you for at least 91 consecutive days and you spend at least one night there (16 nights if it’s a close relative’s home).
- Work tie. You work 3 or more hours a day in the UK on at least 40 days.
- 90-day tie. You spent more than 90 days in the UK in either of the previous two tax years.
- Country tie (leavers only). The UK is the country where you spent the most midnights that year.
Ties are the lever you control: let the flat long-term and stop working from the UK, and you buy yourself far more days. Track them with our day tracker.
Split-year treatment: non-resident from departure day#
Leave in September and you’d normally be resident for the whole tax year. Split-year treatment cuts it into a UK part and an overseas part, but only in three departure cases:
- Case 1: full-time work abroad. You start full-time work overseas and keep your UK days and UK workdays within pro-rated limits.
- Case 2: the partner. Your partner qualifies under case 1 and you move abroad to live with them.
- Case 3: ceasing to have a UK home. You give up your UK home, spend fewer than 16 days in the UK for the rest of the year and, within six months, become tax resident abroad or have your only home there.
All three require that you were UK resident the year before and are non-resident the following year. Tell HMRC with form P85 if you don’t file Self Assessment; if you do, complete the residence pages (SA109). HMRC’s own online service doesn’t accept them, so file on paper by 31 October or use commercial software.
When two countries claim you#
If you still meet the SRT and your new country also treats you as resident, the double tax treaty’s tie-breaker (permanent home, centre of vital interests, habitual abode, nationality) decides where you’re treated as resident for treaty purposes. A treaty is a rescue, not a plan. More on tie-breakers: tax residency explained.
Exit tax: none for individuals, but a five-year trap#
Unlike Germany, where 1% or more of a company can trigger tax on unrealised gains when you leave (§6 AStG, see German exit tax), the UK has no general exit tax for individuals. Leave with a portfolio full of gains and no bill arrives at the border. Companies are different: a company that moves its residence out of the UK is treated as disposing of its assets (section 185 TCGA 1992).
The catch is temporary non-residence. It applies if you were solely UK resident in at least 4 of the 7 tax years before leaving and your period of non-residence lasts 5 years or less. Return within that window and certain income and gains from your time abroad are taxed in the year you come back, including:
- gains on assets you already owned when you left,
- certain dividends from close companies (think: your own company) paid out of profits made before you left,
- certain pension lump sums and some other income listed in the rules.
Sell your company in year two abroad, come back in year four, and the UK taxes the gain after all. Stay away more than five years and the risk ends.
Inheritance tax: residence now, domicile no more#
Since 6 April 2025 domicile no longer decides inheritance tax. You’re a long-term UK resident if you were UK resident in at least 10 of the previous 20 tax years, and then your worldwide assets are in scope. After you leave, that status lingers – the “IHT tail”:
| Years of UK residence before leaving | Still in scope after leaving |
|---|---|
| 10–13 | 3 tax years |
| 14 | 4 tax years |
| 15 | 5 tax years |
| Each further year | One more year, up to 10 |
UK assets such as a London flat stay in UK inheritance tax regardless. After 10 consecutive years of non-residence the test resets. The same reforms replaced the remittance basis with the 4-year FIG regime for newcomers – relevant if you return after 10 years abroad (see the UK country guide).
What stays taxable after you leave#
Non-residents are taxed on UK-source income and on UK land. The usual suspects:
- UK rental income. Under the Non-Resident Landlord Scheme your letting agent (or your tenant if rent is above £100 a week) deducts basic rate tax, unless HMRC approves you to receive rent gross (form NRL1). You still file a return.
- UK property sales. Non-residents pay capital gains tax on UK residential property (since 6 April 2015) and on all UK land, including indirect holdings (since 6 April 2019). Report every disposal within 60 days of completion, even with no tax due or a loss.
- UK employment. Salary for UK workdays stays taxable in the UK.
- UK pensions. Private and workplace pensions are paid under PAYE. If your treaty gives the taxing right to your new country, claim relief with form DT-Individual to get paid without UK tax. Non-residents don’t usually pay UK tax on the State Pension.
- Dividends. The UK levies no withholding tax on dividends. Your new country usually taxes them.
British and EEA citizens keep the personal allowance as non-residents; others may get it through a treaty.
Social security and health cover#
National Insurance and the NHS follow their own rules – and 2026 changed them for people abroad.
- Voluntary contributions. Since 6 April 2026 voluntary Class 2 for periods abroad is gone (narrow exceptions aside). New applicants for voluntary Class 3 need 10 continuous years of UK residence or 10 qualifying years of contributions, up from 3. Class 3 costs £18.40 a week in 2026/27. Existing Class 3 payers carry on; Class 2 payers can switch without the 10-year test if they apply (form CF83) before 6 April 2027.
- State Pension. It’s paid worldwide, but annual increases only follow you to the EEA, Switzerland, Gibraltar and countries with a social security agreement that provides for them. Elsewhere, including Canada and New Zealand, it’s frozen at the rate when you left.
- Working in the EU. Under the UK-EU Trade and Cooperation Agreement’s coordination rules you generally pay into one system at a time, usually where you work. Sent by a UK employer to a country without an agreement, you may still owe Class 1 for the first 52 weeks.
- NHS. Free hospital care depends on being ordinarily resident in the UK, so moving abroad for good ends it. UK State Pensioners in the EU, EEA or Switzerland can get an S1: the UK funds their local healthcare and NHS treatment on visits to England. Everyone else needs local or international cover.
Banks, brokers and ISAs#
- ISAs. You can keep your ISA and its UK tax relief, but you can’t pay in while non-resident (Crown employees excepted). Your new country may tax the income anyway – ISA status is a UK concept.
- Bank accounts. Some UK banks restrict or close accounts once you live abroad. Open a local account first and update your address honestly: under the Common Reporting Standard your UK bank reports the account to your new tax authority anyway.
- Brokers and platforms. Many UK platforms don’t serve residents of certain countries and may make you sell or transfer. Check the terms before you move.
- Pensions. Be wary of anyone pitching an urgent overseas pension transfer. Banking abroad: see offshore banking.
Your UK exit, step by step
Map your SRT position
Count UK days for this year and the next two, list your ties, pick your split-year case.
Deal with the home
Sell, let long-term or give up the lease. An available UK home is the most common reason leavers stay resident.
Time big disposals
Company sales are where temporary non-residence hurts. Plan on more than five years away, or take advice on timing.
Tell HMRC
File P85, or the SA109 residence pages with your return. Sort your PAYE codes and any DT-Individual claim for pensions.
Set up the new side
Register for tax in your new country, get a tax residency certificate and open local banking.
Traps to watch#
Where UK leavers slip
The 16-day cliff.
Leavers get only 15 UK days under the first automatic overseas test. Day 16 sends you to the ties test.
The flat you kept.
An available home creates an accommodation tie and can trigger the home test outright.
Coming back in year four.
Gains and close-company dividends from the years abroad can be taxed on return under temporary non-residence.
Forgetting the IHT tail.
Ten or more years of residence keeps your worldwide estate in UK inheritance tax for at least three years.
Silence on UK property.
Non-residents selling UK land must report within 60 days, gain or no gain.
Missing the NI window.
Voluntary Class 2 abroad has gone; if you were paying it, apply for Class 3 before 6 April 2027.
Worked example: two leavers, same year#
Illustrative only. Priya and Tom both leave London for Cyprus in September 2026 and were UK resident for many years.
| Priya | Tom | |
|---|---|---|
| UK home after leaving | Lets the flat long-term | Keeps the flat “for visits” |
| Split-year case | Case 3 (no UK home, 11 UK days after leaving) | None – still has a UK home |
| 2027/28 UK days | 40 | 70 |
| UK ties in 2027/28 | 90-day tie only | Accommodation, 90-day, work tie |
| 2027/28 result | Non-resident (fewer than 4 ties at 16–45 days) | Resident (3 ties at 46–90 days) |
| Sells company shares in 2028, returns 2030 | Gain taxed in the UK in the year of return | Gain taxed in the UK anyway |
Priya’s exit is clean unless she returns early. Tom is still UK resident and pays for his “visits” flat twice.
Leaving the UK: 12-month plan
Tick them off – your progress is saved in this browser only.
List your shares, UK property, pensions and ISAs. Note how many years you’ve been UK resident for the IHT tail and the 4-of-7 test.
Compare countries on tax, residence rules and life with the Jurisdiction Finder and the country guides. Check the treaty with the UK.
Decide when to sell assets and where your company will be managed after the move. See place of management.
Apply for your residence permit abroad, check your NI record, decide on voluntary Class 3 and price health insurance. Pensioners heading to the EU: apply for an S1.
Sell, let long-term or end the lease. Check whether you’ll fit split-year case 1, 2 or 3.
Open a local account, check which UK banks and brokers keep non-residents, stop ISA contributions.
Keep a day count from departure, file P85 or the SA109 pages, sort PAYE and treaty claims, register with your new tax office.
Watch ties and days every tax year, and keep the more-than-five-years rule in mind before returning.
FAQ#
Does leaving the UK trigger an exit tax?
Not for individuals. But return within five years (after being resident in 4 of the previous 7) and gains on assets you held on departure can be taxed in the year you come back.
How many days can I spend in the UK after leaving?
Fewer than 16 always keeps a leaver non-resident. Beyond that it depends on ties: with one tie you can spend up to 120 days, with four ties only up to 15. Full-time work abroad allows up to 90 days.
Can I keep my ISA when I move abroad?
Yes, with its UK tax treatment, but you can’t add money while non-resident.
Can I still pay voluntary National Insurance from abroad?
Only Class 3 for most people since 6 April 2026, and new applicants need 10 years of UK residence or contributions. Former Class 2 payers can switch until 6 April 2027.
Is my estate still in UK inheritance tax after I leave?
After 10 of 20 years of UK residence, yes, for 3 to 10 years. UK assets stay in scope regardless.
Everything here is general information, not tax or legal advice. For the destination side, see move abroad; want your exit plan checked before you go? Book a strategy session.
Sources#
- Finance Act 2013, Schedule 45 – Statutory Residence Test
- HMRC – RDR3: Statutory Residence Test guidance
- HMRC – Residence and FIG Regime Manual: split year treatment (RFIG21000)
- GOV.UK – Tax if you leave the UK (P85, SA109)
- TCGA 1992, section 185 – company ceasing to be UK resident
- GOV.UK – Inheritance Tax if you’re a long-term UK resident
- HMRC – Inheritance Tax Manual: long-term UK residence test (IHTM47020)
- GOV.UK – Remittance basis changes
- GOV.UK – Tax on your UK income if you live abroad
- GOV.UK – Non-resident Landlords Scheme
- GOV.UK – Capital Gains Tax on UK property for non-residents
- HMRC – Form DT-Individual
- GOV.UK – ISAs if you move abroad
- GOV.UK – Voluntary National Insurance abroad from 6 April 2026
- GOV.UK – Voluntary National Insurance rates
- HMRC – NI38: Social security abroad
- GOV.UK – Countries where the State Pension is increased annually
- GOV.UK – NHS entitlements: ordinary residence
- NHS – Planning your healthcare when living abroad (S1)
