Statutory Residence Test - HM Revenue & Customs

Split Year Treatment
5. Split year treatment
What is a split year?
5.1 Under the SRT, you are either UK resident or non-UK resident for a full
tax year and at all times in that tax year. However, if during a year you either
start to live or work abroad or come from abroad to live or work in the UK the
tax year will be split into two parts if your circumstances meet specific criteria:
a UK part for which you are charged to UK tax as a UK resident;
an overseas part for which, for most purposes, you are charged to UK
tax as a non-UK resident.
5.2 RDR1 provides a broad guide to the taxation of different income sources
to help you determine the impact split year treatment will have on the tax you
pay.
When is a tax year split?
5.3 You must be UK resident for a tax year under the SRT to meet the criteria
for split year treatment for that year. You will not meet the split year criteria for
a tax year for which you are non-UK resident under the SRT.
5.4 Split year treatment in the context of the SRT applies only to you in your
individual capacity. It does not apply to individuals acting as personal
representatives. It applies in a limited way to individuals acting as trustee of a
settlement in determining the trustees’ residence status:
if the individual becomes or ceases to be a trustee of the settlement
during the tax year
provided that the period they are a trustee falls within the overseas part
of the tax year for that individual.
5.5 Split year treatment will not affect whether you are regarded as UK
resident for the purposes of any double taxation agreement.
When will you receive split year treatment?
5.6 There are eight sets of circumstances where you might meet the criteria
for split year treatment for a particular tax year. Three cover situations where
you might go overseas part way through the tax year, these are Cases 1-3,
and five cover situations where you might come to the UK part way through
the tax year, these are Cases 4-8.
5.7 If your circumstances fall within more than one Case of split year criteria
then the Cases must be considered in the following priority order (to
determine which Case/split year date applies to you):
if you were UK resident in the year prior to the tax year in question and
your circumstances for that year fall within two or more of Cases 1 to 3;
RDR3 51