UK SRT split-year treatment: the mandatory review boundary

Full-year residence is the starting rule

Under the SRT, a person is either UK resident or non-UK resident for the whole tax year. A year in which the person is UK resident is split into a UK part and an overseas part only when one of the statutory cases and all its conditions apply.

Split-year treatment is not elective: HMRC says the person does not have a choice when a case applies. The full-year test comes first, and the statutory case and priority rules determine the split date. It is not simple day proration, a chosen move date or a chosen work-start date.

Departure and arrival cases differ

For an actual or deemed departure, RDR3 directs the reader to cases 1 to 3. They cover starting full-time work overseas, being the partner of someone who does so, and ceasing to have a UK home. Each case has detailed relevant-period, day, home or work conditions.

For an actual or deemed arrival, cases 4 to 8 address starting to have a UK-only home, starting full-time UK work, ceasing full-time overseas work, the partner case, and starting to have a UK home. Similar-looking life events can therefore sit in different statutory cases with different dates.

All possible cases and priority rules matter

HMRC identifies exactly eight split-year cases. Every case that might apply must be considered and all conditions of a case must be met. If more than one case applies, priority ordering determines which case governs and where the year is split. Selecting the earliest favourable event is not the statutory method.

Work cases use calculations extending beyond a simple annual total. Home cases require factual analysis of homes and presence. Partner cases have relationship and timing conditions. Exceptional-circumstance adjustments can affect specified limits but do not waive the rest of a case. These dependencies make split year a mandatory review boundary.

Keep treaty and tax effects outside the estimator

Treaty residence is a separate review layer. The Finance Act schedule recognises that enactments can have express contrary effects, and HMRC's wider guidance distinguishes sole UK residence from periods of treaty non-residence. A domestic full-year or split-year worksheet does not decide a treaty tie-breaker or treaty claim.

Split-year treatment can affect how relevant income and gains are treated, while temporary non-residence rules may also matter on return. This guide does not determine those consequences, filing status, filing obligations or tax liability. Preserve the full-year trace, identify candidate cases, and take treaty and split-year facts to the official manual or qualified advice.

Run the full-year SRT first.
Review every potentially applicable split-year case.
Apply statutory priority ordering when cases overlap.
Treat treaty residence and tax consequences as separate review work.

Review return charges and FIG relief separately

Temporary non-residence is a separate return rule. HMRC says a person within its conditions may be charged on return on certain income and gains received or remitted during the temporary non-residence period. The conditions include prior sole UK residence history and the length of the non-residence period; a split-year or SRT result alone cannot decide whether the return charge applies.

From 6 April 2025, the FIG regime can provide claim-based relief to a qualifying new resident after at least 10 consecutive tax years of non-UK residence, during the first 4 years of UK residence. Nationality and domicile do not determine FIG eligibility, and prior remittance-basis amounts have separate rules. A residence result alone does not decide a filing obligation, tax liability or whether any relief claim is available.

Official sources

Sources were checked on 2026-07-16. Linked institutions may update their guidance after that date.