The Split-Location Expat

Introduction

We are entering a new era of global mobility.
People no longer relocate in a clean, predictable, permanent way.

Today, expats:

• work remotely
• work hybrid
• spend months at a time in multiple countries
• maintain family in the UK
• own property in one country
• run a business in another
• educate children abroad
• spend summer back home
• hold investments everywhere
• split life between “home abroad” and “home in the UK”

Their residency patterns are messy.
Beautiful - but messy.
Their lives make sense emotionally - but not to the tax authorities.

Tax authorities assess residence by reference to statutory tests, objective indicators, and treaty principles, rather than lifestyle narratives.

And with the 2025/26 tax reforms, the UK - along with many other countries - is increasing compliance and scrutiny.

Split-location expats are among the higher-risk groups from a residence and compliance perspective.

This article is a guide to how tax really works when you live between multiple countries.

Why Split-Location Expats Are the Most Vulnerable Group

Let’s say you split your life like this:

• 4 months in Dubai
• 3 months in London
• 2 months in Spain
• 3 months in Singapore
  (Or any variation of these.)

Your life looks balanced. Flexible. Free.

But to tax authorities, split patterns can create uncertainty about where residence should be assessed.
In practice, authorities will focus on:
‘Which domestic residence tests apply?’
‘Which ties and connecting factors are present?’
‘Is there treaty dual residence and, if so, how does the tie-breaker apply?”

Here’s the reality:

If you live between countries, you are at increased risk of being resident under the domestic rules of more than one country in the same period, which can increase compliance burden and create double-tax exposure until treaty relief is applied.

The Myth of “Nowhere Tax Resident”

So many expats say:

“I’m not tax resident anywhere.”

It sounds neat.
It feels liberating.
It fits their lifestyle story.

But it’s not true.

It is theoretically possible, but uncommon in practice, to be non-resident under the domestic law of multiple jurisdictions at the same time. However, this position is often difficult to sustain and highly fact specific.

In the UK, residence is not based on nationality - it is determined under the Statutory Residence Test (SRT) using days and ties for the tax year.

The key risk for split-location lifestyles is unintended dual domestic residence, which increases reporting complexity and can create double-tax exposure until treaty relief is correctly applied.

Why the UK Tax System Hates Ambiguity

The UK’s Statutory Residence Test (SRT) was designed to eliminate ambiguity.

But if your life is split between multiple countries, SRT can become complex and easy to misapply.

Here’s why:

1. You accumulate ties quickly

A split-location expat often has:

• Family tie
• Accommodation tie
• Work tie
• 90-day tie
• Country tie

If you have several UK ties, UK residence can be triggered on a much lower day count than most people expect. Depending on whether the individual is treated as an ‘arriver’ or ‘leaver’ for SRT purposes, and which ties apply, UK residence can be triggered at relatively low UK day counts.

Arrivers vs leavers matters: the SRT day-count thresholds depend on whether you are treated as an “arriver” (becoming UK resident after a period abroad) or a “leaver” (having left the UK), and which ties apply in the tax year. This is a common reason split-location taxpayers misapply day thresholds.

2. People miscount days

A day generally counts as a UK day for SRT purposes if you are present in the UK at midnight, subject to limited exceptions (including qualifying transit days).
For example, arriving for an event and staying overnight will typically create a UK day.

Day creep is a common cause of accidental UK residency.

3. People don’t realise remote work can count as a UK workday for SRT purposes

Work duties performed while physically present in the UK (including remote or digital work) can count as UK workdays for SRT purposes.

Filling in a report at a café in London?
UK workday.

If UK workdays reach the relevant threshold (commonly 40+ UK workdays, with a workday typically 3+ hours), this can create a work tie for the sufficient ties test.

{{INSET-CTA-1}}

The Tie-Breaker Rules Everyone Gets Wrong

It’s possible to be treated as resident under the domestic law of more than one country in the same period. Where a Double Tax Treaty applies, its tie-breaker rules are used to determine treaty residence (for treaty purposes) and help allocate taxing rights and relieve double taxation.

These are the tie-breaker rules:

1. Permanent Home

Where can you actually live permanently?

2. Centre of Vital Interests

Where is your real life?

This includes:

• spouse
• children
• property
• business activity
• social life
• roots
• long-term base

Many split-location individuals find this test difficult because their personal and economic links are spread across countries, and the analysis can point to the UK more often than expected.

3. Habitual Abode

Habitual abode considers where an individual habitually lives over the relevant period, taking into account the frequency, duration and regularity of stays in each country. Outcomes are fact-specific — particularly for people who genuinely spend substantial time in multiple countries — so this should not be assumed to default to any one country without analysing the pattern.

4. Nationality

Where nationality is reached as a tie-breaker (which is relatively rare), UK nationality can be determinative if the other country does not share nationality, subject to the specific treaty wording.

5. Mutual agreement procedure

A long, complex negotiation - nobody wants it.

Mutual agreement procedures exist to resolve treaty residence disputes, but they can take time and require detailed evidence. The aim is to avoid reaching this point by keeping travel, homes, family ties and economic links consistent with the intended residence outcome.

UK Policy Changes (2025/26 onwards): why split-location patterns need extra care

Several UK policy changes from 6 April 2025 onwards increase the importance of getting UK residence status, timing, and reporting right—particularly where someone’s life is genuinely spread across more than one country.

1. Remittance basis reform (from 6 April 2025)
   The UK is moving away from the previous remittance basis approach for non-domiciled individuals and introducing a new framework (including a four-year foreign income and gains regime for qualifying new arrivals), with detailed conditions and transitional rules. Whether this helps or not is highly fact-dependent and will typically interact with UK residence status.
2. Inheritance Tax: long-term UK residence concept and “tail”
   Legislation introduces a long-term UK residence concept for IHT (broadly, UK-resident in 10 of the previous 20 tax years, subject to the detailed statutory conditions and transitional rules). There is also a tail that can keep individuals within scope for a period after ceasing UK residence, depending on their residence history. Split-location patterns can make it easier to meet (or re-meet) the relevant thresholds inadvertently.
3. Income tax rate changes affecting non-employment income (announced)
   Budget announcements and policy documents have referred to changes affecting the taxation of dividends, savings and property income, with the precise impact depending on enacted legislation and commencement provisions.
4. National Insurance: ongoing changes and consultations
   National Insurance rules (including voluntary contributions) have been subject to change and consultation in recent years (for example, proposals around Class 2). Entitlement to pay voluntary contributions and the impact on State Pension position are fact-dependent (work history, residence and contribution record), so this should be checked rather than assumed.
5. International data sharing and compliance
   Cross-border information exchange (including under CRS/AEOI frameworks) continues to increase the visibility of cross-border financial arrangements and residence indicators. This makes consistent record-keeping (travel, workdays, accommodation availability, and filings) more important where life is genuinely split across jurisdictions.

Common Split-Location Case Patterns

The following anonymised case patterns reflect situations we frequently see with split-location individuals. Each appears reasonable on the surface, but creates complexity once UK residence rules, overseas domestic tests and treaty principles are applied.

Case Pattern 1 — Low UK days, high UK ties

Typical profile:

• Relatively low UK day count spread across the year
• A UK home available (owned, rented, or regularly used family home)
• Family connections remain in the UK

Why issues arise:
Under the UK Statutory Residence Test, multiple ties can significantly reduce the UK day threshold at which residence may arise. Individuals often underestimate the impact of accommodation and family ties when UK visits are frequent but short.

Potential outcome:
UK residence for the tax year, with worldwide income and gains potentially within UK scope, subject to reliefs, regimes and any treaty position.

Case Pattern 2 - Dual domestic residence and treaty reliance

Typical profile:

• Time split broadly evenly between the UK and another country
• A home available in both jurisdictions
• Social, economic and personal links spread across both

Why issues arise:
It is possible to be resident under domestic law in more than one country at the same time. Treaty tie-breakers apply a strict hierarchy and can produce results that differ from personal expectations.

Potential outcome:
Increased compliance burden, possible initial double taxation until treaty relief is claimed, and a need for strong supporting evidence.

Case Pattern 3 - Remote work during UK visits

Typical profile:

• Non-UK resident (or intending to be)
• Works remotely while visiting the UK
• UK workdays not formally tracked

Why issues arise:
Work performed while physically present in the UK can be relevant for SRT tie analysis and for employment income allocation under domestic law and treaties, even if thresholds for a “work tie” are not met.

Potential outcome:
Unexpected reporting requirements, employment income allocation issues, and increased difficulty defending non-residence.

Case Pattern 4 - UK board and director activity

Typical profile:

• UK board meetings attended in person
• Director or advisory fees received
• Assumption that limited UK presence is immaterial

Why issues arise:
Director duties performed in the UK can create UK-source exposure under domestic rules and many treaty provisions, regardless of overall residence position.

Potential outcome:
UK reporting and potential tax exposure linked specifically to UK board activity.

Case Pattern 5 - Major transactions in a change-of-residence year

Typical profile:

• Disposal of investments, business interests or pension benefits
• UK presence increases in the same tax year
• Residence status not reviewed before the transaction

Why issues arise:
UK residence is assessed for the tax year as a whole (with split-year treatment applying only in defined circumstances). Timing of transactions relative to residence status can materially affect tax scope and reporting for UK residence years and temporary non-residence scenarios.

Potential outcome:
Transactions expected to fall outside the UK tax net become reportable or taxable in the UK, depending on the facts and treaty position.

Key takeaway:
Split-location living does not fail because of one dramatic mistake. It fails because multiple small assumptions interact with residence tests, treaties and timing in ways people do not anticipate. Clear records, deliberate planning and consistency across years are what keep these scenarios manageable.

The Emotional Cost of Being “Double Resident”

This is an aspect that’s often overlooked.

Being double resident isn’t just financially expensive - it’s emotionally draining.

You feel:

• exposed
• confused
• overwhelmed
• frustrated
• wrongly judged
• misunderstood
• ashamed
• scared you’ve “done something wrong”
• anxious you’ll lose money you worked hard for
• worried what else you’ve missed

It hits self-esteem.
It hits confidence.
It hits family stability.

Tax is not technical at this level.
It’s personal.

And that’s why this guide exists —
to protect split-location expats from the pain they never saw coming.

Employment Income: How Remote Work Creates Residence and Allocation Risk

Remote work is the single most misunderstood area for split-location expats.

We meet people who say:

I live in Dubai but I sometimes work from the UK — is that okay?”
It depends. Make sure you track UK workdays and understand how UK duties interact with residence analysis and treaty allocation.

Here’s the truth:

UK work duties performed while physically present in the UK can be relevant both for SRT residence analysis and for the allocation of employment income under domestic law and applicable treaties.

For SRT specifically, the “work tie” is generally triggered only where you work in the UK on 40 or more days in the tax year, with a “workday” typically involving 3 or more hours of work in the UK.

Even where the SRT work tie is not triggered, UK workdays can still be relevant for treaty allocation, employer compliance, and overall risk management — so they should be tracked carefully.

Example:

You spend:

• 4 months in Dubai
• 3 months in the UK
• 5 months between Spain, Singapore, and the US

You think:
“I’m still non-resident.”

But you did:

• 40 workdays in the UK
• stayed in your parents’ home
• did a few London meetings
• spent > 90 days in the UK across 2 years

In this type of fact pattern, UK residence can arise at relatively low UK day counts, depending on the individual’s SRT classification and applicable ties.

Director Income: The Board Meeting Problem

Director and board remuneration can be taxed under specific domestic rules and treaty provisions (many treaties include a dedicated directors’ fees article). UK board attendance and UK duties can still create UK-source exposure and compliance obligations, so it’s important to analyse both the domestic position and the relevant treaty article.

So if you:

• fly into London
• sit in board meetings
• sign documents
• attend strategy sessions
• participate in a board vote

→ Director duties performed in the UK can give rise to UK-source income under domestic law and many treaty provisions relating to directors’ fees.

This is especially impactful if you:

• own a business
• sit on multiple boards
• advise UK companies
• invest in UK startups
• take dividends linked to directorships

Pensions: Managing Residence, Treaty and Timing Risk

Pensions are one of the most technically sensitive areas for split-location expats.

The rules change depending on:

• where you are resident
• where your pension is held
• where the DTA assigns taxing rights
• whether you have UK workdays
• whether you took the pension before or after residency
• whether you triggered UK residency mid-year

Common issues:

1. Taking a pension lump sum abroad - then accidentally becoming UK resident that year

If you take a lump sum in a tax year in which you are UK resident (and split-year treatment does not limit the period), the UK tax position may be materially different than expected, depending on the type of pension, the payment, and treaty provisions.

Government service pensions often have special treaty treatment and may be taxable in the paying state (commonly the UK), but the result depends on the specific treaty wording and conditions.

2. Taking pension income in a hybrid year

If you become UK resident under SRT in a tax year, pension income received in that year may fall within UK taxing rights, subject to split-year treatment and any applicable treaty provisions.

3. Government pensions

Government service pensions are often taxable in the paying state (frequently the UK), subject to the specific wording of the relevant double tax treaty.

4. QROPS misunderstandings

Some split-location expats wrongly assume QROPS makes UK tax irrelevant.

It doesn’t.

5. DTA rules misunderstood

Some treaties assign pension taxation exclusively to the country of residence.
Others give UK exclusive rights.
Others depend on the type of pension.

Split-location expats often mess this up badly.

Dividends, Interest, Investments: The “Invisible Residency” Problem

Investment income is one of the areas where an unexpected UK residence outcome can significantly change tax scope and reporting.
In general, UK residents are taxed on worldwide income and gains, subject to reliefs/regimes (for example, treaty relief and, where eligible, the 4-year foreign income and gains regime). The timing and scope can also be affected by split-year treatment and the nature/source of the income.

UK Property for Split-Location Expats

UK property can be a major residence and reporting factor for split-location individuals.
Here are the key areas to understand:

- Rental income remains within UK taxing scope

UK property rental income is generally taxable in the UK, regardless of where you are resident, although the final position can depend on your circumstances and any applicable reliefs or treaty interaction.

- UK CGT can apply to disposals of UK property by non-residents

Being non-UK resident does not remove UK CGT exposure on UK property disposals, and reporting/payment obligations can apply. The outcome depends on the nature of the asset, the disposal, and the individual’s wider UK tax position.

- SDLT surcharges may apply for certain non-UK resident purchases

Acquiring residential property in England/Northern Ireland can attract the 2% non-resident SDLT surcharge where the conditions are met, and this can apply in addition to the higher rates for additional dwellings where relevant.

- Non-resident reporting is time-sensitive (and doesn’t wait for Self-Assessment)

Disposals of UK land/property by non-UK residents are generally within UK CGT and can require a UK property return (and any CGT payment) within the relevant deadline (often within 60 days of completion for UK residential property disposals), even if you also file a UK tax return.
If you return to UK residence in the same tax year, review the wider CGT position at the same time (for example, how other disposals are taxed in the return year, including any temporary non-residence implications and whether split-year treatment is in point).

- A UK home being available can increase UK residence risk

Having accommodation available in the UK can create an accommodation tie under SRT and may increase the likelihood of UK residence depending on day counts and other ties. In practice, UK property is often a key factor that must be managed carefully within a split-location plan.

The New Residence-Based IHT System (10/20 Rule): Why Residence History Now Matters More

From April 2025, the UK moves to a residence-based framework for IHT, with residence history becoming a key driver of whether non-UK assets fall within scope, subject to the legislation and transitional rules.

- Long-term UK residence (10/20 concept)
Where the statutory conditions are met (broadly, UK-resident in 10 out of the previous 20 tax years), non-UK assets can fall within scope for UK IHT.
- A statutory ‘tail’ may apply after leaving the UK
Depending on residence history and the detailed rules, IHT exposure to non-UK assets can continue for a period after ceasing UK residence.
- Returning to UK residence can affect future exposure
Subsequent periods of UK residence can change the analysis going forward, depending on how the rules apply to your residence history.
- Split-location patterns need monitoring
Split-location lifestyles can make it easier to meet (or re-meet) relevant thresholds inadvertently, especially where time in the UK increases over multiple years.

A common story:

A British expat lived in the UK until age 32, left for 12 years, but now splits time between UK/Spain/Dubai.

He thinks:

“I’ve been out for over a decade - I’m safe.”

But his history:

• 18–32 = 14 years in the UK
• Overseas since = 12 years

He is already in the 10/20 window.

Meaning:

If he dies while the long-term residence conditions (or any applicable tail provisions) apply to him, his non-UK assets may still be within scope for UK IHT, depending on the detailed rules and any transitional provisions.
Subsequent UK residence can affect the position going forward, so the key is to track residence history and plan deliberately.
For split-location individuals, IHT is one of the main areas where multi-year patterns matter as much as what happens in a single tax year.

Compliance & Reporting: Split-Livers Face Double the Burden

Split-location expats often have:

• UK self-assessment
• overseas tax returns
• CRS (Common Reporting Standard)
• AEOI (automatic exchange of information)
• UK property reporting
• NRCGT reporting
• local bank reporting
• company filings
• trust reports (if applicable)

In practice, split-location living creates more third-party reporting signals (bank/tax reporting frameworks, border and travel records, and residency declarations to financial institutions). The practical takeaway is to keep clean travel records, maintain consistent documentation, and file correctly in each relevant jurisdiction.

The 12 Most Common Mistakes Split-Location Expats Make

These are the most common issues we see:

1. Miscounting days

Day creep is real.

2. Assuming remote work doesn’t trigger residency

It can.

3. Leaving a UK home “available”

Residency risk.

4. Taking dividends while UK resident

Potentially becoming subject to UK income tax.

5. Selling property in a hybrid year

Can produce complex CGT outcomes.

6. Receiving pension income mid-year

Can create unexpected tax scope.

7. Ignoring DTA tie-breaker rules

Critical for residency.

8. Not knowing which country “trumps” on residency

Can materially affect tax exposure and reporting.

9. Assuming a treaty protects everything

Treaties can help, but they do not eliminate domestic filing obligations or remove all double-tax risk.

10. Returning for too long

Can trigger UK residence depending on days/ties and SRT classification.

11. Letting spouse + children stay in the UK

Can increase UK ties and raise UK residence risk.

12. Thinking “I’ll sort it later”

By then, options may be more limited.

The Split-Location Expat Strategy (Step-by-Step)

This is the roadmap every split-location expat needs.

Step 1 - Map your 12-month travel calendar

Track days properly.

Step 2 - Audit your ties

Family
Accommodation
Work
90-day
Country tie

Step 3 - Determine your residency in each country

SRT for the UK
Local tests abroad

Step 4 - Apply the treaty tie-breaker rules

Permanent home
Centre of vital interests
Habitual abode
Nationality

Step 5 - Decide where you WANT to be resident

And plan your life accordingly.

Step 6 - Avoid UK workdays unless absolutely necessary

Or your UK residency will be triggered.

Step 7 - Avoid making the UK your “most days” country

The country tie can be decisive.

Step 8 - Protect pension withdrawals

Time them to residency carefully.

Step 9 - Protect CGT events

Sell only when residency is clear.

Step 10 - Review your IHT position under the 10/20 rule

A split-location lifestyle often triggers this accidentally.

Step 11 - File correctly in each country

Don’t assume exemptions.

Step 12 - Get a joined-up tax strategy

Siloed accountants = high-risk of making mistakes.

Conclusion

Split-location expats are the new normal - but they’re among the higher-risk groups from a residence and compliance perspective.

Living between two countries feels modern, flexible, exciting, global. But the tax system doesn’t see it that way.

It sees:

• inconsistencies
• conflicting signals
• ties everywhere
• day-counts
• residency claims
• centre-of-life confusion
• pension risks
• CGT exposure
• IHT dangers
• DTA misapplications

The good news? With clarity, planning, and the right advice, you can live a global life safely.

You can protect your income.
You can protect your gains.
You can protect your estate.
You can protect your future.

Your lifestyle doesn’t have to cost you financially - approach residency with the same level of structure and planning as other major financial decisions.

And that planning starts now.