UK tax residency 2026: the Statutory Residence Test, FIG regime & rates

How tax residency in the UK works

The UK does not decide residency by intuition or by a single 183-day line. Since 2013 it uses the Statutory Residence Test (SRT), a deterministic flowchart run by HMRC that counts two things: the number of days you are present in the UK in a tax year (the 'midnight' rule — you are present if you are in the UK at midnight), and the number of connecting ties you have to the country. The UK tax year runs 6 April to 5 April, not the calendar year.

Work through the SRT in order: the automatic overseas tests first (which can make you non-resident), then the automatic UK tests (which can make you resident), and finally the sufficient-ties test for everyone in between. Residency then determines the big question: UK residents are taxed on their worldwide income and gains; non-residents generally pay UK tax only on UK-source income.

The Statutory Residence Test, step by step

1. Automatic overseas tests — you are non-resident if you spend fewer than 16 days in the UK in the tax year (or fewer than 46 days if you were not UK-resident in the previous three tax years), or if you work full-time overseas with fewer than 91 UK days and no more than 30 UK working days.
2. Automatic UK tests — you are resident if you spend 183 or more days in the UK in the tax year; or your only home is in the UK for a qualifying period; or you work full-time in the UK across a 365-day period.
3. Sufficient-ties test — if neither set of automatic tests decides it, count your UK ties (family, accommodation, work, 90-days-in-a-prior-year, and — for 'leavers' — the country tie). The more ties, the fewer days you can spend before becoming resident.
4. Check for split-year treatment — in the year you arrive or leave, the year can sometimes be split into a UK part and an overseas part.
5. Confirm your position with HMRC's RDR3 guidance and its online residence tool before you rely on it.

The day thresholds and tie counts interact, so borderline cases turn on careful record-keeping. Keep travel logs — HMRC expects evidence, not estimates.

The FIG regime — what replaced non-dom status

For decades the UK's headline attraction for wealthy movers was non-domiciled status and the remittance basis: foreign income and gains escaped UK tax unless brought into the country. That regime was abolished on 6 April 2025. In its place is the 4-year Foreign Income and Gains (FIG) regime, which is based purely on residence, not domicile.

Under FIG, a 'qualifying new resident' — someone who has been non-UK-resident for at least the ten consecutive tax years before arriving — can elect to have foreign income and gains exempt from UK tax for their first four tax years of residence, whether or not the money is remitted. The election is made annually on the self-assessment return and can cost you your personal allowance and capital-gains annual exemption for that year, so it is a calculation, not a default. After four years, worldwide taxation applies in full.

How your income is taxed

Once you are UK-resident and outside any FIG relief, you pay UK income tax on worldwide income at progressive rates. For the 2026/27 tax year (England, Wales and Northern Ireland; Scotland sets its own bands): a personal allowance of £12,570, a 20% basic rate to £50,270, a 40% higher rate to £125,140, and a 45% additional rate above that. The personal allowance tapers away between £100,000 and £125,140 of income. Capital gains and dividends have their own separate rates and allowances.

Inheritance tax now follows residence

The UK also moved inheritance tax (IHT) from a domicile basis to a residence basis on 6 April 2025. Your exposure to IHT on worldwide assets now depends on how long you have been UK-resident — broadly, becoming a 'long-term resident' once you have been UK-resident for at least ten of the previous twenty tax years, with a 'tail' that keeps you in scope for a period after you leave. This is a major planning point for anyone with significant offshore wealth, and it is worth modelling before you cross the ten-year line.

There is no UK golden visa

Be clear on one point: the UK has no golden visa and no citizenship-by-investment programme. The Tier 1 (Investor) visa — which allowed settlement in exchange for a £2 million investment — closed to new applicants on 17 February 2022 and has no direct replacement. People who want to live in the UK use the immigration system on its merits: the Skilled Worker route, the Innovator Founder route for entrepreneurs with an endorsed business, and family, ancestry or global-talent routes. Most settled routes reach indefinite leave to remain after five years, then citizenship. Immigration status and tax residency are separate questions — you can be tax-resident without settled status, and vice versa.

The upside — why people choose the UK

• A world-class financial centre, deep capital markets, and English-language business by default.
• The FIG regime gives new arrivals four years of tax-free foreign income and gains — genuinely attractive for a defined, planned stay.
• An extensive network of double-tax treaties to relieve double taxation.
• Clear, rules-based residency via the SRT — no discretion once you know your day count and ties.
• A five-year path to settlement and then citizenship on qualifying visa routes, and the UK permits dual citizenship.

Common challenges to plan for

• It is fundamentally a high-tax country — up to 45% income tax and worldwide taxation once FIG runs out.
• The non-dom remittance basis is gone; the FIG replacement lasts only four years and needs ten prior years of non-residence.
• Inheritance tax is now residence-based, so long stays pull worldwide assets into a 40% IHT net.
• The SRT is precise but unforgiving — miscounting days or ties can flip your status and your whole tax bill.
• No golden visa: you need a genuine immigration route, and status is separate from tax residency.

Who it suits

The UK suits people who want a top-tier base for a defined chapter — founders, executives and investors who can make the most of four FIG years, or those with a genuine job, business or family route who value London's finance, schools and connectivity over a low-tax outcome. It suits long-term settlers who want a strong passport. It is a poor fit for anyone seeking a permanent low-tax home.

How Expectat helps

The UK rewards planning and punishes drift. The SRT day-and-ties maths, the four-year FIG clock, the ten-of-twenty IHT line and the separate immigration track all need to be set up before you move, not reconstructed afterwards. We can model your residency position, time your arrival and departure around the tax year, and make sure a FIG election actually pays for itself. Book a strategy call and we'll plan it with you.

Where it fits in a borderless plan

The UK is usually a base or passport flag rather than a tax flag — best paired with a deliberate capital structure and a plan for what happens when FIG ends. Read how to establish tax residency abroad, keep a Bitcoin self-custody plan, and see our UK dual-citizenship guide if settlement is the goal.