An international tax accountant in Manchester should start with residence, timing and source before attempting to calculate the UK tax. We work with internationally mobile professionals, business owners, investors and families whose affairs involve more than one country, foreign income or gains, overseas workdays, pensions or a move into or out of the UK.
Cross-border tax is rarely solved by counting days alone. I would normally establish the client's residence history, homes, work pattern, family ties, overseas income and transaction dates before deciding which UK rules, treaty provisions or reliefs need to be considered.
Give us the countries involved, your UK arrival or departure dates, the principal income or asset involved and any live filing or HMRC deadline.
International tax is not one calculation. Residence determines the starting point, while the nature and timing of income, gains, employment duties and pensions determine what needs to be reported and which reliefs may be available.
Statutory Residence Test reviews for people arriving in, leaving or spending substantial time in the UK, including the detailed split-year conditions where relevant.
UK residence Worldwide incomeUK reporting of overseas dividends, interest, property income and capital gains, including claims under the current four-year FIG regime where the eligibility conditions are satisfied.
Foreign income & gains EmploymentReview of qualifying foreign employment income for newly UK-resident employees whose duties are performed partly outside the UK.
Overseas Workday Relief RetirementUK tax treatment of foreign pension income and lump sums, including residence, the type of pension and relevant treaty provisions.
Overseas pensionsBefore deciding whether foreign income is taxable in the UK, I would establish whether the individual is UK resident for the year, whether split-year treatment applies and when the relevant income or gain actually arose.
The same discipline applies to employment. The fact that salary is paid overseas, or paid by a foreign employer, does not by itself decide the UK tax result. Residence, workdays, the period to which the remuneration relates and any available relief all need to be considered.
Residence for the whole tax year must be established first, followed by the relevant split-year cases rather than simply treating the arrival date as the tax starting date.
A UK resident is normally taxed on worldwide income and gains unless a specific relief applies, so leaving the funds abroad does not itself remove the UK tax question.
Work location, residence, payroll and treaty rules may all be relevant, particularly where the employment began before or continues after a move to the UK.
Foreign tax does not automatically settle the UK liability. Treaty provisions and foreign tax credit relief may need to be considered to determine which country has taxing rights and how relief is given.
Cross-border tax is highly dependent on facts and dates. The relevant information usually extends beyond the income statement itself because residence, work patterns, homes and earlier tax years can change how the current year is treated.
UK days, workdays, homes, family connections and prior UK residence are reviewed tax year by tax year.
We establish when foreign income arose and when assets were disposed of rather than relying simply on when money reached a bank account.
UK and overseas duties, remuneration periods, bonuses and payroll treatment are considered where employment spans countries.
Tax paid overseas, treaty residence and the character of the income are reviewed before deciding how double taxation relief should operate.
The UK rules changed materially from 6 April 2025. The former remittance-basis system was replaced by a residence-based regime, so historic non-domicile assumptions should not simply be carried forward into current returns.
Residence is determined separately for each tax year under the Statutory Residence Test. The analysis can involve automatic overseas tests, automatic UK tests and the sufficient ties test. A person spending 183 days or more in the UK is UK resident, but residence can arise with fewer days.
Statutory Residence Test guidance ↗From 6 April 2025, a qualifying new resident can claim relief on qualifying foreign income and gains during the first four years of UK residence after at least 10 consecutive tax years of non-UK residence. Claims are made year by year and do not automatically carry forward.
Four-year FIG regime ↗From 6 April 2025, qualifying newly UK-resident employees may claim Overseas Workday Relief on qualifying foreign employment income. The annual financial limit is the lower of 30% of qualifying employment income for the relevant year or £300,000.
Overseas Workday Relief guidance ↗Foreign dividends, interest, overseas property income and other foreign income can fall within UK taxation for a UK resident. Where another country also taxes the same income, treaty provisions or foreign tax credit relief may reduce double taxation.
UK taxation of foreign income ↗The complexity usually comes from timing and connection rather than nationality alone. A single move, bonus, pension withdrawal or asset disposal can involve more than one country's rules and more than one UK tax year.
We establish residence and the relevant dates before analysing income or gains. That avoids applying the right tax rule to the wrong part of the tax year.
We establish residence history, arrival or departure dates, UK days, homes, employment pattern, countries involved and any previous UK filing position.
Foreign income, employment remuneration, disposals, pensions and overseas tax are matched to the relevant tax years and periods.
We prepare the agreed residence analysis, tax calculation, claim or return and deal with any implementation or HMRC work included in scope.
International tax questions often sound simple until residence history, workdays and the timing of income are examined. The correct answer normally depends on the chronology rather than nationality or the location of a bank account alone.
UK residence is determined separately for each tax year under the Statutory Residence Test. The test considers automatic overseas tests, automatic UK tests and, where necessary, your UK ties and number of UK days. Residence therefore cannot safely be decided from nationality, immigration status or one isolated day-count rule.
No. Spending 183 days or more in the UK makes you UK resident, but a person can also become resident with fewer days under the other automatic UK tests or the sufficient ties test. Your previous residence status and connections with the UK can materially affect the day thresholds.
No. You first determine whether you are UK resident for the tax year. If you are resident, the statutory split-year cases must then be considered. Each case has detailed conditions and its own split date. Where a case applies, split-year treatment is part of the statutory residence analysis rather than simply a choice to use your physical moving date.
From 6 April 2025, UK residents are normally taxed on their worldwide income and gains on the arising basis. Qualifying new residents may be able to claim relief under the four-year Foreign Income and Gains regime, and particular income can also be affected by treaty provisions or another specific relief.
It is a residence-based relief introduced from 6 April 2025. Broadly, an individual can be a qualifying new resident where they are within their first four UK-resident tax years after at least 10 consecutive tax years of non-UK residence. A claim can be made for qualifying foreign income, gains or both, but eligibility and the consequences of making the claim should be reviewed for the particular year.
Overseas Workday Relief can provide relief for qualifying foreign employment income of an eligible newly UK-resident employee where duties are performed outside the UK. Under the post-April 2025 regime, the relief is subject to an annual financial limit equal to the lower of 30% of the relevant qualifying employment income or £300,000.
Paying foreign tax does not necessarily mean the income is excluded from UK taxation. A double tax treaty may determine which country has primary taxing rights, while foreign tax credit relief can sometimes give credit against the UK liability. The correct treatment depends on the income type, residence position and treaty concerned.
Foreign pension income can be taxable in the UK where the recipient is UK resident, but the result can depend on the type of pension, the payment involved and the relevant double taxation agreement. Government and public-service pensions can require particularly careful treaty analysis.
The fee depends on the scope. A residence review with a clear travel history is different from analysing several tax years, foreign employment, overseas investments, pensions and tax already paid in multiple jurisdictions. We establish the countries, tax years, issues and required deliverables before agreeing the fee. Our general pricing approach is explained on Our Fees .
