What is a split year for UK tax purposes?
Answered 17 March 2026
What is a "Split Year" for UK Tax Purposes?
What the law says
A "split year", in relation to an individual, means a tax year that, as respects that individual, is a split year within the meaning of Part 3 of Schedule 45 to the Finance Act 2013 (Statutory Residence Test: split year treatment). The same definition is replicated across the income tax and capital gains tax legislation.
References in legislation to "the overseas part" or "the UK part" of a split year are to be read in accordance with Part 3 of Schedule 45 to the Finance Act 2013.
HMRC guidance / practice
The core concept
Under the Statutory Residence Test (SRT), an individual is normally either UK resident or non-UK resident for a full tax year. However, 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 may be split into two parts:
- A UK part — for which the individual is charged to UK tax as a UK resident.
- An overseas part — for which, for most purposes, the individual is charged to UK tax as a non-UK resident.
Who it applies to
Split year treatment is only available to an individual who is resident in the UK for that tax year. It typically arises where an employee arrives in or departs from the UK part way through a tax year.
It is not optional
An individual who is UK resident for a year is obliged to consider whether split year treatment applies. If they meet all the conditions of one of the cases of split year, it will be applied — the individual has no choice.
Effect on tax
Any overseas earnings relating to the overseas part of the split year are excluded from the employee's UK taxable earnings for that year. However, earnings for the overseas part remain taxable in the UK if they relate to duties performed in the UK or an overseas Crown employment subject to UK tax.
Effect on residence counting
A year in which split year treatment applies is still counted as a full year of UK residence for residence-counting purposes (e.g. the 10-year non-residence test), because the individual is resident under the SRT for the full tax year.
Priority rules
If an individual meets the conditions of more than one "case" of split year, priority ordering rules apply (see RFIG21030).
Historical position
For the tax year 2012–13 and earlier, Extra Statutory Concession ESC A11 provided a form of split year treatment before the SRT was introduced.
Citation sources
rate ” in relation to a tax year, means the Scottish basic rate set by a Scottish rate resolution for that year ... “Scottish intermediate rate”, in relation to a tax year, means any Scottish rate for that year which is named “intermediate” by the Scottish rate resolution setting it, “Scottish rate” in relation to a tax year, means a rate set by a Scottish rate resolution for that year, “Scottish rate resolution” means a resolution of the Scottish Parliament under section 80C of the Scotland Act
Under the SRT, an individual is 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 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-U
Treaty non-residence (see RFIG50300) and split year treatment (see RFIG21010) are ignored for the purposes of the residence criteria, both in considering the tax year of claim and the 10 or more consecutive tax years of non-UK residence. This means that an individual who is UK resident under the SRT (or see HMRC6 for 2012-13) will be UK resident for the purposes of considering the criteria, regardless as to whether an individual could have been deemed resident in another jurisdiction as a resul
An employee may arrive in or depart from the UK part way through a tax year. If the individual becomes resident during the year of arrival or leaves the UK having established residence, the year may be treated as a split year for tax purposes. For tax years from 2013-14, section 15 ITEPA 2003 provides that the year may be split into a UK part, when an employee will be charged to tax as resident in the UK, and an overseas part which will be a period when an employee will be taxed as though they a
Split year treatment is only available if you are resident in the UK for a tax year. You will need to consider your circumstances across the entire tax year before you consider if you qualify for split year treatment and from what date the year will be split.
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