International Tax Matters

Clear advice from Chartered Tax Advisers for people and businesses whose tax affairs cross borders.

For individuals moving to or from the UK

UK residence and split-year treatment
The new foreign income and gains (FIG) regime for new arrivals
Overseas Workday Relief
Foreign income, gains and double tax relief
Reporting overseas assets and accounts correctly

Share awards from overseas employers

RSUs, share options and employee share purchase plans
Income tax on vesting and how it interacts with payroll
Capital gains on sale, applying HMRC's share matching rules
Apportioning awards for people who have worked in more than one country

For businesses

Cross-border group and holding company structures
Transfer pricing
Overseas entities and UK reporting obligations

Frequently asked questions

I'm moving to the UK. When do I become UK tax resident?
Residence is decided by the Statutory Residence Test, which looks at the days you spend in the UK and your ties here, such as a home, work or family. In the year you arrive, split-year treatment may mean you are only taxed as a UK resident from your arrival date. The rules are detailed, so it's worth taking advice before you move.
What is the FIG regime?
From 6 April 2025, the remittance basis was replaced by the foreign income and gains (FIG) regime. If you become UK resident after at least 10 consecutive tax years of non-residence, you can claim relief on foreign income and gains for your first four years of UK residence. The relief has to be claimed on your tax return, and claiming it has consequences, such as losing your personal allowance and capital gains tax annual exempt amount for that year.
What is Overseas Workday Relief?
Overseas Workday Relief can exempt the part of your employment income that relates to work done outside the UK. From 6 April 2025 it is available for the first four tax years of UK residence to those who qualify for the FIG regime, and is capped at the lower of 30% of qualifying employment income and £300,000 a year. Good records of where you worked each day are essential.
How are RSUs from my overseas employer taxed?
RSUs are generally taxed as employment income when they vest, often through payroll. When you later sell the shares, any growth in value is subject to capital gains tax, and HMRC's share matching rules decide which shares are treated as sold. If you worked in more than one country between grant and vesting, part of the income may be taxable elsewhere instead.
Will I pay tax twice on income that has been taxed abroad?
Usually not. Double tax relief, under a tax treaty or the UK's own rules, generally lets you set foreign tax against the UK tax on the same income, although the relief may not always cover the full amount.
Do I need to tell HMRC about overseas income or accounts?
If you are UK resident, you will generally need to report foreign income and gains on your Self Assessment tax return unless a relief applies. HMRC receives information about overseas accounts from other tax authorities, so complete returns matter. If something was missed in earlier years, it can usually be corrected through HMRC's Worldwide Disclosure Facility.
I'm leaving the UK. What should I consider?
Split-year treatment may apply in the year you leave, and you may need to tell HMRC about your departure. If you return within five years, some income and gains received while you were away can become taxable in the UK, so it is worth planning disposals and payments carefully.

Need advice on an international tax matter?

Speak to an RMHO adviser about your international position.

Speak to an Adviser

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