From Residence, Domicile and Remittance Basis Manual 12010:

If during a year the individual starts to live or work abroad, or comes from abroad to live or work in the UK, the tax year will be split into 2 parts, if their circumstances meet specific criteria:

  • a UK part for which they will be charged to UK tax as a UK resident
  • an overseas part for which, for most purposes, the individual will be charged to UK tax as a non-UK resident.

Then, from Residence, Domicile and Remittance Basis Manual 12020:

An individual must be UK resident for a tax year under the SRT to meet the criteria for split year treatment for that year. They will not meet the split year criteria for a tax year for which they are non-UK resident under the SRT.

SRT stands for Statutory Residency Test and, as I previously expounded in this thread, I pass the test and I am indeed a tax resident for 2019-2020, even if only lived there from 6 April 2019 to 1 August 2019.

This is the part from Document 12020 that confuses me:

Split year treatment will not affect whether the individual is regarded as UK resident for the purposes of any double taxation agreement.

Isn't the whole point of the split-year treatment to affect the status of UK residency during the overseas part? That is, one is indeed a non-UK resident for that period of time?

1 Answer 1


No, you're either a resident or a non-resident for the full year. Split year treatment just means you don't have to pay tax to the UK for the overseas part, but you're still considered UK tax resident for the whole year.

BTW, from your other post it seems you only lived in the UK for a few months. In this case, split year treatment would not apply since split year treatment requires you to be a resident for the following tax year (when moving to the UK) or the previous year (when leaving). See this HRMC publication.

  • For a few months in the 2019-2020 tax year. I moved to the UK in 2017 and, as per my thorough answer here, I am a UK tax resident for 2019-2020 and I am eligible for the split-year treatment. In any case. Fine. I am tax resident for the whole year. Do I also have to pay UK tax on the capital gains I made while overseas, considering that I bought and sold the assets after I left the UK? Apr 24, 2020 at 12:41
  • 1
    @PaulRazvanBerg For the capital gain tax question, my answer to a similar question might help.
    – TripeHound
    May 24, 2020 at 14:27
  • @PaulRazvanBerg Critical clarification: are you also considered a resident for tax purposes in the other country, for the period in question? Depending on the country and its associated tax treaty with the UK, this might be a specific edge case they reference, or it might not. Typically you should expect that for a common modern tax treaty, barring very unfortunate circumstances, any tax you pay to one country should offset tax to the other country, such that your net tax paid between both countries is simply equal to the highest rate between the two. Sep 17, 2021 at 14:38
  • @Grade'Eh'Bacon Yes, in 2019 I was also considered a tax resident in Romania. Sep 17, 2021 at 16:07

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