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    TaxKilnUK tax guidance

    Moving Abroad → EU framework post-Brexit

    EU Framework Post-Brexit — Withdrawal Agreement + TCA + Reference for France, Portugal, Italy, Germany, Netherlands

    Post-Brexit, UK nationals moving to or living in EU member states fall into two distinct legal regimes. (1) Withdrawal Agreement (WA) protected rights — UK nationals lawfully resident in an EU member state before 31 December 2020, with continuing lawful residence, retain extensive Free Movement, healthcare, social security and pension uprating rights. (2) Post-2020 arrivers fall under destination-country immigration framework plus the UK-EU Trade and Cooperation Agreement (TCA), in force 1 May 2021, which includes a Protocol on Social Security Coordination but does NOT preserve Free Movement. This page is the framework reference for the EU corridor generally and the post-launch deep dives on France, Portugal, Italy, Germany and Netherlands.

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    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

    Two cliffs. Pre-31-December-2020 UK arrivers in EU member states sit under the Withdrawal Agreement — they keep most of the substantive rights they had as EU citizens: continuing residence, healthcare under S1, aggregation of social security periods across EU and UK, UK State Pension uprating, free movement within EU for short periods. Post-2020 arrivers move under destination-country immigration regimes (Non-Lucrative Visa, Digital Nomad Visa, work visas) and the UK-EU TCA — Title VII Protocol on Social Security Coordination preserves some pension and contribution-aggregation mechanics, but Free Movement is gone. Direct destination-country implications for the corridor: SPAIN — Golden Visa REPEALED April 2025 (all routes); Non-Lucrative Visa and Digital Nomad Visa remain; Beckham Law expanded by Ley 28/2022. PORTUGAL — NHR (Non-Habitual Resident) regime closed to new applicants January 2024, replaced by IFICI ('NHR 2.0') with narrower scope. ITALY — Impatriati regime expanded post-2024. FRANCE — UK-France DTA + Assurance Vie + IFI (Impôt sur la Fortune Immobilière, replacing the old ISF). GERMANY — UK-Germany DTA + 6-month residence rule + church tax (Kirchensteuer) for self-declared religious affiliates. NETHERLANDS — UK-Netherlands DTA + Dutch 30% ruling (similar in spirit to Beckham Law; meaningfully different mechanics).

    How it works

    Withdrawal Agreement protected rights — pre-31-December-2020 arrivers

    Substantive protections retained: continuing right of residence in the host EU member state under EU Free Movement principles (subject to host-state residence administrative requirements); access to host-state healthcare on the same basis as nationals (UK S1 form continues to fund retirees' healthcare in host state where applicable); aggregation of UK and EU social security periods for State Pension entitlement under WA Article 30; UK State Pension uprating in the host EU member state continues; cross-border professional qualifications recognition retained for those qualified pre-2021. Family-reunification rights extended to certain post-2020 family arrivals. WA rights are personal — they do not transfer if the holder loses lawful residence in the host state for more than 5 consecutive years.

    Post-2020 arrivers — destination-country framework + TCA

    No Free Movement. UK nationals require destination-country residence permit under that country's immigration regime: work visa (employment-sponsored), self-employed visa, retired/passive-income visa (Spain Non-Lucrative Visa; Portugal D7 passive-income visa; France long-stay visa for retirees), or digital-nomad visa where available (Spain Digital Nomad Visa via Ley 28/2022; Portugal Digital Nomad Visa). UK-EU TCA Title VII Protocol on Social Security Coordination preserves: detached-worker rules; aggregation of contribution periods for State Pension entitlement; UK State Pension uprating in EU member states (continuing); aggregation of healthcare entitlement in narrowly-defined situations. Cross-border professional qualifications no longer auto-recognised — host-state recognition processes required.

    Spain-specific — Golden Visa repeal and remaining visa pathways

    Organic Law 1/2025 (in force 3 April 2025) REPEALED the entire investor-residence regime under Title V of Ley 14/2013. All four investment routes ended: €500,000 property purchase; €1m bank deposits; €2m Spanish public debt; €1m company shares or business investment. The 'Wealth Visa' / Visa Inversor was discontinued for new applicants from 3 April 2025; existing holders retained their rights through their permit's expiry. Pathways remaining for UK nationals: NON-LUCRATIVE VISA (passive income / pensions, no Spanish work permitted; €28,800+ annual income proof); DIGITAL NOMAD VISA (introduced by Ley 28/2022, remote work for non-Spanish employer); WORK VISA (sponsored by Spanish employer); HIGHLY-QUALIFIED PROFESSIONAL VISA; STUDENT VISA; FAMILY REUNIFICATION.

    EU corridor framework reference — other destinations

    PORTUGAL: NHR (Non-Habitual Resident) regime closed to new applicants from 1 January 2024 via Decree-Law 41/2023. Existing NHR holders retain 10-year regime. Replacement is IFICI under Lei 82/2023 — narrower scope, limited to high-value-added scientific/innovation roles; not a general HNW retiree regime. UK-Portugal DTA 1968 (with 2017 protocol) governs. ITALY: Impatriati regime expanded by Italian Budget Law 2024 — 50% Italian income tax exemption (up from 70%) for new arrivers meeting prior-non-residence and registered-residence conditions, 5 years duration. Italy-UK DTA 1988. FRANCE: ISF wealth tax abolished 2018; replaced by IFI (Impôt sur la Fortune Immobilière) — real-estate-only wealth tax above €1.3m. UK-France DTA 2008. GERMANY: 6-month residence rule under AO Section 9 triggers German tax residence. Church tax (Kirchensteuer) is additional levy of 8-9% of income tax for self-declared religious affiliates — declaration on Anmeldung registration form. UK-Germany DTA 2010. NETHERLANDS: 30% ruling (Decree IZV 2001-1271M) allows qualifying expat employees to receive up to 30% of salary tax-free for 5 years (reduced from 8 years in 2019); ongoing 2024-2026 reforms phase down the relief to a 27% / 24% / 21% staggered structure. UK-Netherlands DTA 2008.

    Who this applies to + key conditions

    Statute + manual references

    Primary: EU-UK Withdrawal Agreement (in force 1 February 2020; transition period to 31 December 2020). EU-UK Trade and Cooperation Agreement (provisional application from 1 January 2021; in force 1 May 2021).

    Related: WA Article 13-15 (residence rights), Article 18 (right of residence permit), Article 30 (social security coordination); TCA Protocol on Social Security Coordination (Title VII Part Two); Spain Organic Law 1/2025 (Golden Visa repeal, in force 3 April 2025); Portugal Decree-Law 41/2023 (NHR closure) plus Lei 82/2023 (IFICI replacement regime); Italy DL 209/2023 (Impatriati 2024 reform); France: ISF abolition (PLF 2018) + IFI replacement on real estate; Germany: AO Section 9 (residence test), Einkommensteuergesetz; Netherlands: 30% ruling under Decree IZV 2001-1271M (subject to ongoing reform)

    HMRC manual: HMRC RDR1 plus INTM ranges (UK side of EU bilaterals)

    Common mistakes + traps

    Worked example

    Two UK retirees — Ana (moved to Spain in 2019) and Ben (planning to move in 2026)

    Ana moved from Birmingham to Valencia in 2019 with her Spanish residence certificate issued 1 October 2019. Ben is planning to move from Manchester to Valencia in mid-2026. Both are UK State Pension recipients with UK private pensions.

    1. Ana — pre-31-December-2020 arrival, WA protected: continuing residence under WA Article 13 (TIE issued with Withdrawal Agreement annotation). UK State Pension uprated annually via WA Article 30 / TCA Protocol. UK private pension treated under UK-Spain DTA Art. 17 (residence state — Spain). Healthcare via S1 form funded by UK NHS until State Pension age reached; thereafter via S1 retirement healthcare in Spain. Aggregation of UK NI contributions and Spanish Seguridad Social periods for any future Spanish State Pension entitlement.
    2. Ben — post-2020 arrival: requires Spanish visa — Non-Lucrative Visa is appropriate for a UK retiree with passive income proof above €28,800 plus dependants' supplements; no Spanish work permitted. Application via Spanish consulate in London before travel. Once in Spain, residence card (TIE) issued under the new immigration regime (not WA). UK State Pension still uprated via TCA Protocol on Social Security Coordination. UK private pension still treaty-allocated to Spain (residence state) under DTA Art. 17. Healthcare: NOT covered by S1 retirement healthcare unless State Pension age reached AND specific conditions met; otherwise Convenio Especial (Spanish public healthcare buy-in, ~€60-160/month depending on age) or private insurance.
    3. Both subject to Spanish residence determination (Art. 9 LIRPF; see /moving-abroad/spain/srt-and-spanish-residence-test), Modelo 720 disclosure (above €50k category thresholds), Spanish wealth tax / ISGF (above thresholds in Valencia regional regime).
    4. Ben should also consider Beckham Law if he were a working professional rather than retiree — see /moving-abroad/spain/beckham-law-special-regime.

    Outcome: Ana retains the substantively wider WA protected-rights package, particularly around healthcare and Free Movement within EU. Ben's TCA-based position preserves pension uprating and many social security aggregation rights but requires a destination-country residence permit, faces healthcare cost considerations and has no Free Movement onward to other EU states. Both face identical Spanish IRPF, wealth tax and Modelo 720 positions as Spanish residents — the WA / TCA distinction is on residence rights, healthcare and Free Movement, not on Spanish tax substance.

    How this connects to the rest of the framework

    UK State Pension + social security →

    UK State Pension uprating in Spain operates via the TCA Protocol on Social Security Coordination.

    SRT plus Spanish residence test →

    Spanish residence determination is country-specific; framework here covers cross-EU comparators.

    Beckham Law special regime →

    Spain's main HNW special regime; compared here with Portugal NHR/IFICI, Italy Impatriati, Netherlands 30% ruling.

    UK-Spain DTA mechanics →

    Spain bilateral DTA contrasted here with the wider set of UK-EU DTAs.

    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.
    Is the Spanish Golden Visa really completely repealed?+
    Yes. Organic Law 1/2025 (BOE 3 January 2025, in force 3 April 2025) repealed Title V of Ley 14/2013, which was the entire statutory basis for the investor-residence visa. All four investment pathways ended on 3 April 2025: €500,000 property; €1m bank deposit; €2m Spanish public debt; €1m company investment. The previous narrative that only the property route was being closed (or that other routes remained) was overtaken by the final legislation, which repealed the whole regime. Existing Golden Visa holders retain their rights through their current permit's natural expiry. No new applications from 3 April 2025.
    Is my UK State Pension uprated in EU member states?+
    Yes — fully uprated in EU member states (and EEA/Switzerland) via the TCA Protocol on Social Security Coordination, regardless of arrival date pre- or post-2020. UK State Pension paid to a recipient in Spain (or any EU member state) is increased annually by the same percentage as the UK domestic uprating. This contrasts with 'frozen pension' countries (Australia, Canada, New Zealand, most Commonwealth states) where UK State Pension is paid at the rate in force on the recipient's first payment date abroad and never increased. EU residence preserves uprating — a meaningful retirement-planning factor.
    Did Portugal NHR really close — or is it still open in some form?+
    The original NHR regime closed to new applicants on 1 January 2024 via Decree-Law 41/2023. Existing NHR holders retain their full 10-year benefit through the natural end. The replacement regime — IFICI (Incentivo Fiscal à Investigação Científica e Inovação) under Lei 82/2023 — is much narrower in scope, focused on high-value-added scientific research, innovation and qualifying skills shortage roles. It is NOT a general HNW retiree regime. Common informal reference to it as 'NHR 2.0' overstates the continuity; substantively the broad-based NHR for retirees, professionals and remote workers is closed.
    Can I still get UK-funded healthcare in Spain post-2020?+
    Pre-2020 WA-protected residents continue full UK-funded healthcare entitlement under the S1 / S2 framework. Post-2020 arrivers: limited S1 entitlement for UK State Pension recipients reaching State Pension age while in Spain (the UK funds healthcare in country of residence for State Pension recipients in EU member states), governed by the TCA. Posted workers under A1 / S1 detachment rules continue UK-funded healthcare during the posting. Outside these narrow pathways, post-2020 arrivers must access Spanish public healthcare via Convenio Especial (resident buy-in for the public system) or carry private health insurance.

    Free + regulated-body resources

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