International Tax & Treaties UK —
Navigating UK Tax With a Global Footprint

The SRT counts days present in the UK at midnight. Arriving one day and leaving the next counts as one day, not two. Common errors include failing to count transit days correctly and overlooking the exceptional circumstances extension. We calculate UK days precisely for every client.

Many non-residents overpay UK tax by failing to claim treaty relief on their UK return. If you pay tax on the same income in your country of residence, you are entitled to credit — up to the UK tax rate. Not claiming means paying full UK tax without offset. We review the applicable treaty for every international client.

Non-UK residents receiving UK rental income who don’t register with HMRC’s NRLS allow their letting agents to deduct basic rate tax from rents before payment. Registration allows rents to be paid gross — with tax paid annually via Self Assessment after deducting all allowable expenses. We register all non-resident landlord clients with the NRLS as standard.

Non-UK residents are still subject to UK income tax on UK-source income (rental income, employment income for UK workdays, UK pension income) and UK CGT on UK property disposals. The UK’s tax reach extends significantly beyond UK residents — we establish the complete UK tax position for every international client.

UK tax residence is determined by the Statutory Residence Test (SRT) from April 2013. The SRT has three stages: automatic overseas tests (definitively non-resident in certain circumstances), automatic UK tests (definitively UK resident) and the sufficient ties test (days in UK combined with personal, accommodation, work and other ties). The SRT is complex — getting it wrong has significant tax consequences. We apply it precisely.

Yes — where the UK has a treaty with your country of residence, it typically provides for either: exemption from UK tax on certain income types, or credit for UK tax against your overseas tax liability (or vice versa). The specific provisions depend on the treaty. Most UK treaties follow the OECD Model — we review the specific applicable treaty for every client and claim all available relief on your UK Self Assessment return.

NRLS is HMRC’s scheme for taxing UK rental income received by non-UK residents. Without registration, letting agents (or tenants paying rent directly) must withhold basic rate tax from rents before payment. With registration (HMRC approval required), rents can be paid gross — with tax accounted for via annual Self Assessment, after deducting all allowable expenses. Registration almost always produces a better cash flow outcome.

Domicile is a concept of private international law — broadly, the country you regard as your permanent home. Non-UK domiciled individuals living in the UK can elect the remittance basis — paying UK income tax and CGT only on overseas income and gains remitted (brought) to the UK. Unremitted overseas income and gains are not taxable in the UK. The remittance basis charge applies for 7+ year UK residents (£30,000/year) and 12+ year residents (£60,000/year). We model whether the remittance basis is beneficial for each client.

A UK permanent establishment (PE) broadly means a fixed place of business in the UK (office, warehouse, factory) or a dependent agent who habitually concludes contracts in the UK on behalf of an overseas company. Where a UK PE exists, the overseas company is subject to UK Corporation Tax on profits attributable to the PE. An overseas company can inadvertently create a UK PE by having UK-based managers signing contracts or by using UK facilities — we assess PE risk for every international business client.