Note: I know this is a highly specific question, but I'm posting it here because I already talked to two professional tax advisers and they did NOT know the answer.

I was born in Romania and lived there all my life, prior to September 2017 when I moved to the UK. I went there to study, but I dropped out in 2018. In January 2019, I started a full-time job and began paying my taxes to HMRC via the PAYE system. I quit in June 2019 and finally returned back to Romania in August 2019. Between August 2019 and 5th of April 2020 (end of tax year in the UK), I bought and sold shares and cryptocurrencies and made some capital gains, with some assets bought before I left the UK and sold afterward and others bought and sold exclusively afterward.

Figuring out my tax residency and duties for 2019-2020 seems to be a pain in the ass:

  1. I pass the Statutory Residency Test, so I am classified as a tax resident in the UK, at least from UK's domestic point of view
  2. I also pass the "permanent home" tiebreaker from the UK-Romania double taxation agreement, so I am also a tax resident in Romania

Therefore, I think I am a dual resident and have always been one since 2017, due to having a permanent home in Romania.

Where should I declare and pay my Capital Gains tax in 2019-2020? Should I apply the split-year treatment and do it in the UK in the first part of the year, then in Romania for the remaining period, OR should I do it wholly in Romania, because of the permanent home tiebreaker?

  • 1
    (based on zero information about UK and Romania) I would assume that you just pay the taxes in the UK and the tax treaty between the two countries should prevent you from paying taxes twice when you file your tax return in Romania. – xyious Apr 24 at 17:23

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