A 5,000-word reference covering every part of the SRT — the automatic tests, the sufficient ties test, the connecting ties definitions, split year treatment, and twelve worked examples showing how the rules apply to real situations.
The UK Statutory Residence Test (SRT), introduced from 6 April 2013, was intended to bring certainty to UK tax residency determination. Before 2013, residency was determined by case law and HMRC practice, leading to significant uncertainty. The SRT replaced this with a statutory framework — but the framework is complex, with multiple tests, exceptions, and interactions that can produce surprising results. This guide is a 5,000-word reference that covers every part of the SRT, with twelve worked examples showing how the rules apply to real situations.
The SRT has a two-part structure: the automatic tests and the sufficient ties test. An individual is UK resident in a tax year (6 April to 5 April) if they meet any of the automatic residence tests, OR if they meet the sufficient ties test. An individual is non-UK resident if they meet any of the automatic overseas tests, OR if they do not meet any of the automatic residence tests and do not meet the sufficient ties test.
If any of the automatic overseas tests are met, the individual is non-resident for the tax year, regardless of any other factors. There are four automatic overseas tests:
If the individual was UK resident in at least one of the previous three tax years, and they spend fewer than 16 days in the UK in the current tax year, they are non-resident.
If the individual was not UK resident in any of the previous three tax years, and they spend fewer than 46 days in the UK in the current tax year, they are non-resident.
If the individual works full-time overseas (without significant breaks), and they spend fewer than 91 days in the UK in the current tax year, and the number of days they work in the UK is fewer than 31, they are non-resident.
If the individual works full-time overseas as a cross-border worker (defined in the regulations), with at least 75% of their workdays overseas, and they spend fewer than 91 days in the UK, they are non-resident. This test is for individuals who work across borders (e.g., living in France and working in the UK).
If any of the automatic residence tests are met, the individual is UK resident for the tax year, regardless of any other factors. There are five automatic residence tests:
If the individual is present in the UK for 183 days or more in the tax year, they are resident. A day counts as a UK day if the individual is present in the UK at midnight at the end of that day. This is the most straightforward test and the one most people are familiar with.
If the individual has a home in the UK for at least 91 days (continuous), is present in that home for at least 30 days, and either has no home overseas or has a home overseas but is present in it for fewer than 30 days, they are resident. The "home" must be available to the individual for at least 91 continuous days, and the individual must actually use it for at least 30 of those days.
If the individual works full-time in the UK for any period of 365 days (without significant breaks), and more than 75% of the total workdays in that 365-day period are UK workdays, they are resident. The "full-time" requirement is at least 35 hours per week.
This test applies in the year of death if the individual was UK resident in at least one of the previous two tax years and the UK was the individual's main residence at some point in the previous two tax years.
This test applies in the year of death in specific circumstances relating to home ownership.
If neither the automatic overseas tests nor the automatic residence tests are met, residency is determined by the sufficient ties test. This test counts the individual's "connecting ties" to the UK and compares the number of ties against the number of UK days.
The five connecting ties are:
The number of connecting ties required to make an individual resident depends on the number of UK days:
| UK days | Resident in UK in any of previous 3 years? | Ties required for residence |
|---|---|---|
| 0–15 | Yes/No | Always non-resident |
| 16–45 | Yes | 4 or more |
| 16–45 | No | Always non-resident |
| 46–90 | Yes | 3 or more |
| 46–90 | No | 4 or more |
| 91–120 | Yes | 2 or more |
| 91–120 | No | 3 or more |
| 121+ | Yes/No | Always resident |
The matrix creates different thresholds depending on whether the individual was UK resident in any of the previous three tax years. The thresholds are stricter for those who were previously resident — they are considered to retain more ties to the UK.
Counting UK days is fundamental to the SRT. The general rule is that a day counts as a UK day if the individual is present in the UK at midnight at the end of that day. There are specific exceptions:
The day of arrival and the day of departure both count as UK days if the individual is present at midnight on those days. An individual who arrives on Monday and leaves on Wednesday has 2 UK days (Monday midnight and Tuesday midnight — assuming they leave before Wednesday midnight).
Split year treatment allows the tax year to be split into a UK-resident part and a non-UK-resident part. Without split year, the individual is either resident or non-resident for the entire tax year, which can create significant tax issues in the year of arrival or departure. Split year treatment is available in specific circumstances defined in the SRT.
Split year applies if the individual leaves the UK to work full-time overseas (Case 1), or to live overseas (Case 2), or to retire overseas (Case 3). The conditions for each case are specific:
Split year applies if the individual comes to the UK to work full-time (Case 4), to live in the UK (Case 5), or after a period of non-residence (Case 6). The conditions are similar to the leaving cases but in reverse.
Under split year, the individual is treated as UK resident for the part of the year before the split date and non-resident for the part after (or vice versa for arrivals). Income arising in the non-resident part is not taxable in the UK (subject to the remittance basis if applicable). Capital gains in the non-resident part are not taxable in the UK.
Split year treatment is not automatic — it must be claimed on the Self Assessment tax return. The conditions are strictly applied by HMRC, and incorrect claims are a common cause of tax disputes.
To illustrate how the SRT applies in practice, here are twelve worked examples covering common expat scenarios.
John, a UK resident, takes a job in Dubai starting 1 September. He was UK resident in the previous 3 tax years. He spends 60 days in the UK in the tax year of departure (April-August before he leaves, plus a Christmas visit). He has 1 connecting tie (he retains his UK house, which he lets out — this is an accommodation tie if he uses it for at least 1 night in the tax year; if he does not use it, no tie).
Analysis: John does not meet any automatic overseas test (he spends more than 16 days in the UK). He does not meet any automatic residence test (he spends fewer than 183 days; assuming he does not use the UK house, he does not have a home tie). Under the sufficient ties matrix: 46–90 UK days, previously resident, 1 tie — non-resident (requires 3+ ties).
Result: non-resident, subject to split year treatment if Case 1 conditions are met.
Mary, a UK citizen, has lived in Australia for 10 years and has been non-UK resident throughout. She visits the UK for 100 days in the tax year for family reasons. She has 2 connecting ties (family — her elderly mother lives in the UK and Mary stays with her; accommodation — she uses her mother's house, which counts as an accommodation tie).
Analysis: Mary does not meet any automatic overseas test (she spends more than 46 days). She does not meet any automatic residence test. Under the sufficient ties matrix: 91–120 UK days, not previously resident, 2 ties — non-resident (requires 3+ ties).
Result: non-resident. But if Mary had 3 ties (e.g., if she also worked in the UK for 40+ days), she would be resident.
David works in London Monday-Wednesday and lives in Paris. He arrives in London on Monday morning and leaves on Wednesday evening, every week. He spends approximately 156 days in the UK per tax year.
Analysis: David spends 156 UK days (Monday and Tuesday midnights count as UK days for each weekly trip). He does not meet any automatic overseas test (he spends more than 91 days, so the full-time overseas work test does not apply). He does not meet any automatic residence test (fewer than 183 days). He has at least 2 connecting ties (work — he works 40+ days in the UK; accommodation — if he has a UK residence available for 91+ days). Under the sufficient ties matrix: 91–120 UK days — wait, 156 days is in the 121+ range — always resident.
Result: resident. David needs to either reduce his UK days to fewer than 121, or accept UK residency.
Sarah, a UK citizen working in Switzerland, visits the UK frequently for work and family. She spends 184 days in the UK in the tax year.
Analysis: Sarah meets automatic residence test 1 (183+ days). She is resident regardless of any other factor.
Result: resident. Sarah must file a UK Self Assessment return and is taxable on worldwide income (subject to the Switzerland-UK tax treaty and any applicable reliefs).
James owns a flat in London that he rents out. He lives in Singapore. He visits the UK for 30 days per year for work and stays in hotels. He does not stay in his London flat.
Analysis: James does not meet any automatic overseas test (he spends more than 16 days but fewer than 46, so he meets automatic overseas test 2 — wait, this requires fewer than 46 days AND not resident in previous 3 years; let me re-examine). Assuming James was resident in the UK in the previous 3 years (he recently moved), automatic overseas test 1 requires fewer than 16 days — not met. He does not meet any automatic residence test (fewer than 183 days; the flat does not count as a home because he does not use it). Under the sufficient ties matrix: 16–45 UK days, previously resident, ties — depends on whether the flat counts as an accommodation tie. The flat is available to James for 91+ days (he owns it), but he does not use it for at least 1 night in the tax year — so no accommodation tie. If he has no other ties, he is non-resident.
Result: non-resident (assuming no other ties).
Priya lives in India but consults for UK clients. She visits the UK for 60 days per year and works from a co-working space. She has no UK home and no UK family.
Analysis: Priya does not meet any automatic overseas test. She does not meet any automatic residence test. She has 1 connecting tie (work — she works 40+ days in the UK). Under the sufficient ties matrix: 46–90 UK days, not previously resident (assumed), 1 tie — non-resident (requires 4+ ties).
Result: non-resident.
Ahmed has been non-UK resident for 5 years, living in the UAE. He visits the UK for 50 days per year, spread evenly across the four quarters (12-13 days per quarter). He has 1 connecting tie (accommodation — he stays with family).
Analysis: Ahmed meets the country tie (he is present in the UK at midnight on at least 1 day in each of the 4 quarters). Under the sufficient ties matrix: 46–90 UK days, not previously resident, 2 ties (accommodation + country) — non-resident (requires 4+ ties).
Result: non-resident. But if Ahmed had 4 ties, he would be resident.
Helen leaves the UK on 1 July to take up full-time employment in Singapore. She was UK resident in the previous 3 tax years. She spends 50 days in the UK in the tax year of departure (April-June before she leaves, plus a Christmas visit). She works full-time in Singapore from 1 July.
Analysis: Helen does not meet any automatic overseas test. She does not meet any automatic residence test. Under the sufficient ties matrix: 46–90 UK days, previously resident, ties — she may have an accommodation tie (if she retains a UK home), a family tie (if her spouse remains in the UK), and a work tie (if she works 40+ days in the UK before leaving). If she has 3+ ties, she is resident; if she has fewer than 3, she is non-resident.
Split year: if Helen meets Case 1 (full-time work overseas), the tax year is split. She is resident from 6 April to 30 June and non-resident from 1 July to 5 April. Singapore income from 1 July is not taxable in the UK (subject to the remittance basis if she brings it to the UK).
Result: depends on the number of ties, with potential split year treatment.
Robert has a UK home (his former residence) that he lets out. He lives in Spain. He visits the UK for 30 days per year and stays in his UK home for 5 of those days (between tenants). The home is available to him for the entire year.
Analysis: The home is available to Robert for 91+ continuous days (the entire year), and he uses it for at least 1 night in the tax year — so he has an accommodation tie. If he has no other ties, under the sufficient ties matrix: 16–45 UK days, previously resident, 1 tie — non-resident (requires 4+ ties for 16–45 days if previously resident).
Result: non-resident (assuming no other ties). But if Robert stayed in the home for 30+ days, he might meet automatic residence test 2 (home in the UK for 91+ days, present for 30+ days, no overseas home or overseas home used for fewer than 30 days).
Emma is a UK citizen studying for a master's degree in the US. She returns to the UK for 90 days each summer (June-August). She was UK resident in the previous 3 tax years (she left for the US only last September). She has 2 connecting ties (family — her parents live in the UK; accommodation — she stays with her parents).
Analysis: Emma does not meet any automatic overseas test. She does not meet any automatic residence test. Under the sufficient ties matrix: 46–90 UK days, previously resident, 2 ties — non-resident (requires 3+ ties).
Result: non-resident. But if Emma had 3 ties (e.g., if she also worked in the UK for 40+ days), she would be resident.
Michael is a freelance software developer based in Ireland. He has 3 UK clients and visits the UK for client meetings 1 day per week (approximately 50 days per year). He has no UK home, no UK family, and was not UK resident in the previous 3 years.
Analysis: Michael does not meet any automatic overseas test. He does not meet any automatic residence test. He has 1 connecting tie (work — he works 40+ days in the UK). Under the sufficient ties matrix: 46–90 UK days, not previously resident, 1 tie — non-resident (requires 4+ ties).
Result: non-resident.
Susan retires from her UK job and moves to Portugal on 1 October. She was UK resident for the previous 10 years. She spends 180 days in the UK in the tax year of departure (April-September before she moves, plus a Christmas visit). She has 2 connecting ties (family — her adult children live in the UK; accommodation — she retains a UK flat).
Analysis: Susan spends 180 days in the UK — under automatic residence test 1 (183+ days), she is just under the threshold. Under the sufficient ties matrix: 121+ UK days — always resident.
Result: resident. Susan is UK resident for the entire tax year, unless she qualifies for split year treatment under Case 3 (retiring overseas). Case 3 requires that she was UK resident for at least the previous 4 tax years (yes), that she becomes non-resident (this is determined under the SRT — she is resident under the sufficient ties test, so she does not meet this condition), and other conditions. Split year is not available. Susan is resident for the entire tax year.
The SRT requires detailed record-keeping, particularly of UK days. HMRC can challenge residency status years after the fact, and the burden of proof is on the taxpayer. The recommended records:
Records should be retained for at least 4 years after the end of the tax year (the normal HMRC assessment window), but 6 years is safer to cover extended assessment windows.
The UK Statutory Residence Test is a complex framework that determines UK tax residency through a combination of automatic tests and a sufficient ties test. The automatic tests provide certainty at the extremes (very few or very many UK days), while the sufficient ties test handles the middle ground through a matrix of days and ties. The day-counting rules, the connecting tie definitions, and the split year treatment all have specific conditions that must be carefully applied.
For most expats, the SRT analysis is straightforward at the extremes — clearly resident if 183+ days, clearly non-resident if very few days — but becomes complex in the middle. The most common mistakes are underestimating the number of UK days (transit days, partial days), overlooking connecting ties (particularly the accommodation tie and the country tie), and failing to claim split year treatment when eligible.
The cost of getting residency wrong is significant — UK tax on worldwide income, plus penalties and interest for non-filing. The cost of professional advice (typically GBP 500–2,000 for a residency determination) is small relative to the potential tax liability. Use our Income Tax Comparator for the headline take-home comparison, but for the residency determination itself, engage a UK tax specialist who can apply the SRT to your specific facts.
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