Moving Abroad → Returning to the UK
Returning to the UK — SRT, s.10A Catch-Up, FIG Regime, ISA + Property Mechanics
Returning to the UK triggers SRT re-application from the return year. Split-year arrival cases 4-8 may apply. The 5-year temporary non-residence catch-up (TCGA 1992 s.10A) may apply if you return within 5 full tax years — gains realised during non-residence on pre-departure assets wash back into year of return. The 4-year FIG (Foreign Income + Gains) regime is available if you've been non-UK-resident for 10+ tax years.
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In plain English
Coming back to the UK reopens UK residence under SRT. Split-year cases 4-8 may give you part-year non-resident treatment for the year of return. If you've been non-resident for fewer than 5 full tax years, the s.10A catch-up may pull gains realised during non-residence back into the year of return (on assets you held BEFORE leaving). If you've been non-resident for 10+ full tax years, the 4-year FIG regime offers a temporary shelter for foreign income and gains. UK property held throughout: rebasing date for CGT depends on the regime — for residential the April 2015 NRCGT rebasing remains. ISAs retain their wrapper protection while you're abroad (no contributions allowed during non-residence, but existing investments continue tax-sheltered for UK tax purposes); contribution rights resume on UK residency. UK pensions resume normal UK tax treatment.
How it works
SRT on return — Automatic UK Tests + Sufficient Ties + split-year cases 4-8
Apply SRT to the return year. If you pass an Automatic UK Test (183 days, only-home, full-time UK work) you're UK-resident. Otherwise Sufficient Ties Test using arriver thresholds (different from leaver thresholds — generally more generous day-count allowances). Split-year cases 4-8 (Schedule 45 Part 3): • Case 4: starting to have a UK home • Case 5: starting full-time work in UK • Case 6: ceasing full-time overseas work • Case 7: partner of someone ceasing full-time overseas work • Case 8: starting to have a UK home (different facts pattern) Multiple cases can apply; priority order matters. Claim split-year via SA109 box 3.
5-year temporary non-residence catch-up (s.10A) on return
Triggered if all of: • UK-resident in 4+ of the 7 pre-departure tax years • Return to UK residence within 5 FULL tax years of becoming non-resident (the split-year departure year doesn't count as a full year for this purpose) • Gains realised during non-residence on assets held BEFORE leaving Mechanics: gains treated as accruing in the year of return; taxed at that year's CGT rates; using that year's AEA. NRCGT-regime UK property gains already taxed under NRCGT are NOT caught (carve-out to prevent double-charge). Clean exit: 5 full UK tax years non-resident before returning. People who left mid-2020/21 (split-year departure) need to remain non-resident through to at least 6 April 2026 to clear the s.10A risk on pre-departure UK shares/portfolio gains.
4-year FIG regime — eligibility + claim mechanics
FA 2025. Available to UK residents who were non-UK-resident in each of the 10 tax years immediately preceding the year they become UK-resident. Offers full exemption from UK income tax on foreign income + UK CGT on foreign gains for 4 consecutive tax years from arrival (or election in subsequent years within the 4-year window). Claim via SA — annual election. Once 4 years elapse, normal UK tax treatment resumes on worldwide income + gains. Bringing FIG-sheltered income into UK during the 4 years remains UK-tax-free (no remittance-basis trap of old regime). Key limitation: ONLY for fresh arrivers post-10-year-non-residence. Existing UK residents at 6 April 2025 transitioning off remittance basis have separate transitional relief (rebasing to April 2017 MV on certain assets + temporary repatriation facility TRF for past unremitted income at favourable rate).
ISA, property, pension drawdown on return — practical mechanics
ISAs: wrapper preserved during non-residence; no new contributions while non-resident; resumption of contribution rights on UK residency restored. Returns within wrapper UK-tax-sheltered throughout. UK property held throughout: residential rebasing to April 2015 MV remains the default NRCGT base; on return, normal UK CGT applies to post-rebasing gain on subsequent disposal. PPR relief mechanics resume on actual occupation. UK pension drawdown: normal UK tax treatment resumes on UK-residency restoration. Any tax-relieved pension contributions made while non-resident (e.g. limited £3,600 gross annual relief for non-relevant-UK-income individuals during first 5 years post-departure) credited as basis. QROPS transfers made pre-return: 5-year UK overseas-transfer-charge tax tail per PTM112000 continues regardless of return date.
Who this applies to + key conditions
- SRT on return: apply same Tier 1/2/3 test as leaver, with arriver day-count thresholds in Sufficient Ties
- s.10A catch-up: requires UK-resident in 4+ of 7 pre-departure years AND return within 5 full tax years AND gain on pre-departure-held asset
- FIG regime: requires non-UK-resident for the 10 tax years immediately preceding return + annual election
- ISA contribution resumption: only after UK residency restored (use SA confirmation of residence status)
- FIG and s.10A interact but don't fully overlap — FIG-eligible arriver post-10-years has no s.10A exposure on pre-departure UK assets (out of catch window)
Statute + manual references
Primary: TCGA 1992 s.10A (temporary non-residence); Finance Act 2025 (FIG regime); Schedule 45 FA 2013 (SRT split-year cases 4-8)
Related: Individual Savings Account Regulations 1998 SI 1998/1870 (ISA wrapper + non-residence); ITEPA 2003 ss.579A-579C (UK pension taxation on return)
HMRC manual: RFIG + CG26100 (s.10A) + RFIG70000 (FIG regime, post-April 2025)
Common mistakes + traps
- Returning within 4 tax years assuming UK share gains realised abroad escape — s.10A catches them
- Confusing 'tax year' with 'calendar year' for the 5-full-tax-year s.10A test
- Assuming FIG regime available after short non-residence — requires 10 FULL tax years
- Forgetting to file SA109 split-year claim in return year
- Contributing to ISA while non-resident — invalid + remediable but admin pain
- Assuming NRCGT-paid gain attracts double s.10A charge — explicit statutory carve-out prevents this
- Overlooking IHT LTR clock restart on return — return immediately re-engages worldwide IHT scope if 10/20 test re-met
- Missing temporary repatriation facility (TRF) opportunity for prior unremitted foreign income at favourable rate (transitional only)
Worked example
Priya returns to UK April 2030 after 4 years 6 months in Singapore — UK share disposals during non-residence
Priya left UK October 2025 (Case 1 split-year). Non-resident 2026/27, 2027/28, 2028/29, 2029/30 (4 full tax years). Returns 6 April 2030 — UK-resident from start of 2030/31. She sold UK AIM portfolio in 2027/28 realising £80k gain; UK Singapore-sourced consulting income £150k/year while abroad.
- Step 1 — Full tax years non-resident: 2026/27 through 2029/30 = 4 full years. Less than 5. s.10A catch-up triggered.
- Step 2 — Pre-departure asset test: UK AIM portfolio held pre-October-2025 = pre-departure asset.
- Step 3 — s.10A wash-back: £80k gain treated as accruing in 2030/31 return year. Taxed at 2030/31 CGT rates (assume 24% higher-rate residential / 20% other). Less AEA 2030/31. £80k - £3k = £77k @ 20% = £15,400.
- Step 4 — Singapore consulting income abroad: NOT UK source while non-resident, NOT UK-taxable on return (out of UK scope at the time).
- Step 5 — FIG eligibility check: non-resident 4 full years — less than 10. FIG NOT available.
- Step 6 — Return year SA: split-year Case 5 (starting full-time UK work) or Case 4 (starting UK home) likely applies. SA109 claims split-year + reports £80k washed-back gain.
Outcome: Priya owes ~£15,400 UK CGT in 2030/31 on AIM gain realised during non-residence — s.10A catch despite gain being realised + taxed in Singapore at the time. To avoid this she would have needed to remain non-resident for the full 2030/31 tax year (5 full years post-departure). Singapore tax already paid on the £80k gain may qualify for Foreign Tax Credit under UK-Singapore DTA against the UK CGT liability — check treaty.
How this connects to the rest of the framework
Return-year SRT analysis uses the same Schedule 45 framework — arrival cases 4-8 mirror leaver cases 1-3.
s.10A catch-up mechanics for UK shares + non-property assets — NRCGT regime carved out to avoid double-charge.
FIG regime sits in IT/CGT space — independent of LTR IHT test. Returning to UK starts LTR clock for IHT.
On return, UK source income reverts to normal UK-resident treatment; disregarded income s.811 mechanics no longer apply.
Related downloads
Frequently asked questions
What happens if I miss the Self Assessment deadline?+
Do I need an accountant or can I file Self Assessment myself?+
How do payments on account work?+
Can I claim the 4-year FIG regime on returning to the UK?+
I returned after 6 tax years — do I still face s.10A catch-up?+
What happens to my ISA when I return to the UK?+
How does returning interact with my IHT position?+
Free + regulated-body resources
- HMRC RFIG70000 — 4-year FIG regime guidance →
HMRC manual on FIG regime (search RFIG70000+ for post-April 2025 sections)
- HMRC CG26100 — temporary non-residence (s.10A) →
HMRC Capital Gains Manual on s.10A catch-up mechanics
- LITRG — returning to the UK guide →
Plain-English guide to UK residency restoration mechanics
- CIOT International Tax Committee →
Find qualified UK international tax practitioner for complex return scenarios
- MoneyHelper — pensions on return to UK →
Free + impartial guidance on UK pension mechanics including QROPS transfer-tail rules
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