When circumstances shift quickly, attention naturally focuses on practical relocation issues such as travel arrangements, schooling, accommodation, and business continuity.
Those considerations are understandably important. At the same time, a relocation decision can raise several questions around tax positions that are worth reviewing carefully with professional advisers.
Reassessing the existing tax residency position
A useful starting point is often the original residency position itself. For individuals with UK connections, tax residence is determined under the Statutory Residence Test (SRT). It considers factors including days spent in the UK, work patterns, accommodation availability, and family ties.
It is not uncommon for individuals to assume they have “left the UK” simply because they now live elsewhere. In practice, the test is more nuanced and applies on a year-by-year basis.
Considering how day count limits may change
Unexpected relocation also affects day counts, which remain a central element of tax residency frameworks. Even a temporary return to the UK could bring you closer to your limit of available day counts before you trigger tax residency.
While certain exceptional-circumstances provisions exist in some situations, they are often interpreted narrowly and typically apply only within defined limits.
Reporting by the Financial Times mid-March suggested government officials in UAE are considering temporary leniency in day counting requirements as a result of the conflict. Officials are reluctant to consider blanket statements but instead are saying cases would be looked at on a case-by-case basis. The newspaper reported later how advisors and experts in the UK are expecting less leniency from HMRC.
Reviewing wider governance and business arrangements
Relocation can also have implications for businesses. For entrepreneurs and business owners, where management decisions are made and where strategic control of a company sits are important. Changes in where directors operate or where key decisions take place can alter how structures are viewed from a tax perspective.
Evaluating alternative jurisdictions carefully
When reconsidering their base, individuals may naturally explore other jurisdictions. For many expats considering leaving the UAE, Europe may be the most obvious option.
However, each option comes with its own legal, tax, and practical considerations. Relocation decisions must therefore be considered alongside immigration, business, and family factors rather than solely on tax grounds.
Scott echoed this sentiment, stating that “British nationals face an additional complexity. Securing residence elsewhere post‑Brexit is rarely straightforward. Immigration requirements limit the ability to regularise a relocation retrospectively, which means these decisions need to be approached carefully.”
“All that said, returning to the UK is not necessarily disadvantageous. For those who meet the conditions, the four‑year Foreign Income and Gains (FIG) regime can provide a highly favourable framework – but only if the individual positions themselves correctly before any move is made.”