Moving Abroad → SRT plus AU + NZ residence tests

UK SRT plus AU ATO Four Residence Tests plus NZ IRD Residence (UK to AU + NZ)

Determining tax residence across the UK + AU + NZ requires three independent tests on three different tax-year calendars. The UK applies the Statutory Residence Test (Schedule 45 Finance Act 2013) on a UK fiscal-year basis (6 April to 5 April). Australia applies four statutory residence tests via the ATO under ITAA 1936 s.6(1) and ITAA 1997 — codified in the current ATO public ruling TR 2023/1 — on a 1 July to 30 June year. New Zealand applies the IRD 183-day or permanent place of abode tests under s.YD 1 ITA 2007 on a 1 April to 31 March year. Each test runs independently; treaty tie-breakers (Article 4 in each DTA) resolve dual residence for treaty-allocated income.

Last reviewed: 24 May 2026

Guidance, not advice. We explain the rules, we don't assess your situation. Always seek financial or tax advice from your accountant, or contact HMRC. Read our editorial scope →

In plain English

Three countries, three residence tests, three tax-year calendars. The UK SRT is mechanical and well-documented (see /moving-abroad/srt). The Australian side has four parallel tests under ITAA 1936 s.6(1) plus ITAA 1997: the resides test (factual, common-law), the domicile plus permanent place of abode test, the 183-day plus usual-place-of-abode-and-intent test, and the Commonwealth superannuation test (for AU government employees). The ATO's current public ruling TR 2023/1 governs how the resides test is applied — it superseded the 2017 ruling and weights physical presence and ongoing connections. New Zealand applies two independent tests under s.YD 1 ITA 2007: 183 days in any rolling 12-month period (residence backdated to day 1 of that period), OR permanent place of abode in NZ (a substantive test informed by Diamond v CIR [2015] NZSC 19 — a high evidential bar but not defeated simply by absence). The tax-year asymmetries matter: UK 6 April-5 April; AU 1 July-30 June; NZ 1 April-31 March. A UK April departure can create overlapping windows in all three calendars. Treaty residence (DTA Article 4) overrides domestic outcomes only for treaty-allocated income — domestic filing obligations persist independently.

How it works

UK side — applying the SRT

Run the three-tier SRT in order: Automatic Overseas Tests, then Automatic UK Tests, then Sufficient Ties. Split-year Case 1 (starting full-time work overseas) and Case 3 (ceasing to have a UK home) commonly apply on departure to AU or NZ. Full mechanics at /moving-abroad/srt.

AU side — four tests under ITAA 1936 s.6(1)

(1) Resides test (primary): factual common-law test as applied by TR 2023/1 — physical presence, intent, family and business ties, social arrangements. (2) Domicile plus permanent place of abode: if your domicile is Australian, you are resident UNLESS the ATO is satisfied your permanent place of abode is outside Australia (Harding v FCT [2019] FCAFC 29). (3) 183-day plus intent: 183+ days in Australia in the AU tax year — resident unless the ATO is satisfied your usual place of abode is outside Australia and you have no intention to take up residence. (4) Commonwealth super test: members of certain Commonwealth super schemes are resident regardless. Any one test triggers residence.

NZ side — two tests under s.YD 1 ITA 2007

(1) 183-day test: 183+ days of physical presence in NZ in any rolling 12-month period — residence is backdated to day 1 of the qualifying period. (2) Permanent place of abode (PPOA): an independent substantive test (Diamond v CIR [2015] NZSC 19). Owning an NZ property is not, by itself, a PPOA — but combined with family ties, social presence and continuing connection it commonly is. PPOA can persist through extended absences.

Tax-year asymmetry

UK: 6 April-5 April. AU: 1 July-30 June. NZ: 1 April-31 March. A UK leaver to AU in (say) March will trigger UK split-year Case 1 (April), straddle the AU 2024-25 year (Mar-Jun) plus the AU 2025-26 year (Jul onwards), and partially overlap NZ if any time is spent there. Multiple parallel year-end reckonings apply.

Practical registration — TFN + IRD number

AU: TFN (Tax File Number) via ATO; myGov account for ATO online services; superannuation fund TFN provided to employer. NZ: IRD number via IRD; myIR account. Both are free; no specialist service required.

Who this applies to + key conditions

All individuals moving UK ↔ AU or UK ↔ NZ must run both domestic residence tests independently each year
AU residence triggers worldwide income assessability (subject to Subdiv 768-R temporary resident regime — see separate page)
NZ residence triggers worldwide income assessability (subject to s.CW 27 transitional resident regime — see separate page)
UK residence triggers worldwide arising basis (subject to post-April-2025 FIG regime where relevant)
Where dual-resident under both domestic tests for any window, DTA Article 4 tie-breaker resolves treaty residence

Statute + manual references

Primary: UK: Schedule 45 Finance Act 2013 (SRT). AU: s.6(1) ITAA 1936 (resident definition); ITAA 1997 plus TR 2023/1 (resides test). NZ: s.YD 1 Income Tax Act 2007 (residence). Treaties: UK-AU DTA 2003 Article 4; UK-NZ DTA 1983 Article 4.

Related: TFN (Tax File Number) registration via ATO; myGov / ATO online services; IRD number registration via IRD NZ; Subdiv 768-R ITAA 1997 (AU temporary resident — see separate page); s.CW 27 ITA 2007 (NZ transitional resident — see separate page)

HMRC manual: HMRC RDR3 (SRT guidance); INTM156000+ (UK-AU + UK-NZ treaty residence)

Case law: Diamond v CIR [2015] NZSC 19 — leading NZ authority on permanent place of abode; Harding v FCT [2019] FCAFC 29 — leading AU authority on domicile plus permanent place of abode test

Common mistakes + traps

Assuming a single 183-day test covers all three jurisdictions — UK, AU, NZ each apply different statutory wording
Citing the old AU 2017 resides ruling — superseded by TR 2023/1
Treating NZ permanent place of abode as defeated by extended absence — Diamond v CIR [2015] NZSC 19 says otherwise
Forgetting AU CGT event I1 (deemed disposal of foreign assets on becoming AU resident) — see /moving-abroad/australia-new-zealand/au-firb-and-property
Confusing AU temporary resident (Subdiv 768-R, no 4-yr cap) with NZ transitional resident (s.CW 27, 48-month cap) — different statutes, different countries

Worked example

Matt, a UK national taking a 4-year secondment to Sydney from 1 May 2026

Matt is UK-resident in 2025/26. He moves to Sydney on 1 May 2026 on a sub-class 482 temporary skill shortage visa (qualifying for AU temporary resident status). His family relocates with him. He sells the UK home in April 2026 and rents in Sydney. He retains a UK SIPP and a UK savings account.

UK side, 2026/27: split-year Case 1 (starts full-time work overseas) — UK part 6 April to 30 April 2026; overseas part 1 May 2026 to 5 April 2027 non-resident. Full SRT mechanics at /moving-abroad/srt.
AU side: from 1 May 2026, Matt's intent and physical presence make him AU-resident under the resides test (TR 2023/1). He is AU-resident from 1 May 2026 onwards. AU tax year 2025-26 runs 1 Jul 2025-30 Jun 2026 — he is resident from 1 May to 30 Jun 2026 within that AU year (resident for part-year — apportionment of thresholds applies).
AU temporary resident: Matt holds a sub-class 482 visa, so Subdiv 768-R applies. Foreign income (UK SIPP undrawn growth, UK savings interest) and foreign capital gains are EXEMPT from AU tax for the duration of the qualifying visa — no 4-year cap. See /moving-abroad/australia-new-zealand/au-temporary-resident-and-nz-transitional-resident.
DTA tie-breaker for the overlap window (1 May to 5 April UK SRT split-year window): Matt's permanent home and centre of vital interests are clearly in Sydney from 1 May 2026, so treaty residence = AU from 1 May. UK SRT split-year already aligns.
Registration: TFN application via ATO; myGov account; employer reports through STP (Single Touch Payroll); superannuation fund nominated. UK SA 2026/27 filed with SA109 split-year basis.

Outcome: Matt is UK-resident under SRT split-year Case 1 to 30 April 2026 and AU-resident under the TR 2023/1 resides test from 1 May 2026. He qualifies as an AU temporary resident under Subdiv 768-R (his 482 visa qualifies) — foreign income and capital gains exempt from AU tax for the duration of the visa with NO 4-year statutory cap.

How this connects to the rest of the framework

Statutory Residence Test →

Full UK SRT mechanics, Schedule 45 FA 2013.

UK-AU DTA 2003 →

DTA Article 4 tie-breaker resolves UK-AU dual residence.

UK-NZ DTA 1983 →

DTA Article 4 tie-breaker resolves UK-NZ dual residence.

AU temp resident vs NZ transitional resident →

Concessional regimes available once AU- or NZ-resident under domestic tests.

Frequently asked questions

What happens if I miss the Self Assessment deadline?+

The Self Assessment deadline is 31 January (online filing) for the previous tax year. Miss it and HMRC apply an automatic £100 penalty. Beyond that: £10 per day from 3 months late (capped at £900), 5% of tax due at 6 months late, and another 5% at 12 months late, under Schedule 55 of the Taxes Management Act 1970. If you have a genuine reason (serious illness, bereavement, technical issue with HMRC's systems) you can appeal with evidence; HMRC accepts reasonable excuse appeals in most genuine cases.

Do I need an accountant or can I file Self Assessment myself?+

Legally you can file Self Assessment yourself via gov.uk for free, most simple sole-trader returns (single income source, basic expenses) are realistic to self-file. An accountant adds real value when: your trading profit is above £40,000 (extraction-strategy decisions matter), you have multiple income streams (PAYE + self-employment + property + dividends), you've crossed the £90,000 VAT threshold, you're considering incorporation, or you have an HMRC enquiry. Expect to pay £400-£1,500/year for a typical sole-trader accountant; the cost is itself a deductible expense.

How do payments on account work?+

When your Self Assessment tax bill exceeds £1,000 for the first time, HMRC requires payments on account toward NEXT year's tax. Half the current bill is due 31 January (alongside the current bill); the other half is due 31 July. So your first January after crossing the threshold can hit with a double-bill: last year's balance + first payment on account. Adjust via Form SA303 if you expect next year's income to drop substantially. Payments on account don't apply if more than 80% of your tax is collected via PAYE.

Does the AU temporary resident regime have a 4-year time limit?+

No. The AU temporary resident exemption under Subdiv 768-R ITAA 1997 applies for the duration of the qualifying temporary visa — there is no statutory 4-year cap. The common '4-year' framing is a confusion with the NZ transitional resident regime (s.CW 27 ITA 2007), which IS a separate 48-month regime in a different country under a different statute. See /moving-abroad/australia-new-zealand/au-temporary-resident-and-nz-transitional-resident.

If I am in NZ for 184 days starting in October 2026, when does NZ residence begin?+

Under s.YD 1(3) ITA 2007 the 183-day test triggers NZ residence backdated to the first day of the 183-day qualifying period. If you arrive 1 October 2026 and remain through April 2027, the qualifying period started 1 October 2026 — so NZ residence applies from 1 October 2026 for tax purposes, even though the 183-day count finishes in April 2027.

Can I be AU-resident under the resides test even if I am in Australia for fewer than 183 days?+

Yes. The resides test is factual not numerical — it considers physical presence plus intent plus family and business ties plus social arrangements (TR 2023/1). A senior executive who establishes a family home in Sydney in May with only 120 days of physical presence by 30 June can still be AU-resident under the resides test from May.

Free + regulated-body resources

ATO — Residency tests →
Definitive ATO guidance plus TR 2023/1
IRD — Tax residency →
Definitive IRD guidance on NZ residence
HMRC RDR3 (SRT guidance) →
Definitive HMRC SRT guidance