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UK Expats Dubai Tax Residence SRT Guide 2026

Practical 2026 guide for UK residents relocating to Dubai and the UAE: HMRC Statutory Residence Test automatic overseas tests, sufficient ties, UK day counting, temporary non-residence, UAE Tax Residency Certificates, UK-UAE treaty residence and cross-border tax compliance.

Moving From the UK to Dubai: Residence Comes Before Tax Outcomes

Moving to Dubai does not automatically make an individual non-UK resident. UK residence is determined separately for each tax year under the Statutory Residence Test (SRT). The analysis starts with the automatic overseas tests and automatic UK tests, followed where necessary by the sufficient-ties test. The fact that the UAE does not generally impose individual personal income tax on employment income does not by itself decide UK residence.

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The SRT applies separately to each UK tax year.
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If an individual spends 183 days or more in the UK in the tax year, the first automatic UK test makes them UK resident.
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If no automatic UK or overseas test settles the position, the sufficient-ties test is used.
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The third automatic overseas test can apply to someone who genuinely works full-time overseas, but HMRC uses a statutory sufficient-hours calculation rather than a simple contractual-hours rule.
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A UAE Tax Residency Certificate is evidence of UAE tax residence for the FTA's purposes; it does not itself override UK domestic residence.
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For treaty purposes, UK-UAE dual residence is analysed under the UK-UAE DTA's residence article and tie-breaker rules.

Automatic Overseas Tests for People Moving to Dubai

HMRC has three automatic overseas tests for individuals other than deceased persons. The first two are based mainly on UK day counts and residence history. The third applies where an individual works full-time overseas and satisfies the detailed overseas-work, UK-workday and UK-day-count conditions.

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The Test 1 and Test 2 day limits are thresholds: 15 days can satisfy Test 1, while 45 days can satisfy Test 2.
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Test 3 is not simply a '90-day allowance'. The individual must also satisfy the full-time overseas work calculation.
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Test 3 counts days on which more than 3 hours of work is done in the UK; the limit is fewer than 31 such days.
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A significant break from overseas work can cause the full-time-overseas test to fail.
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The test can apply to employees and self-employed individuals, subject to the statutory exclusions.
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Six or more cross-border trips in a relevant job can prevent use of the third automatic overseas test in certain circumstances.
Automatic Overseas TestUK Day ConditionOther Key Condition
Test 1Fewer than 16 UK daysUK resident in at least 1 of the previous 3 tax years.
Test 2Fewer than 46 UK daysNot UK resident in any of the previous 3 tax years.
Test 3Fewer than 91 UK daysFull-time overseas work, fewer than 31 UK workdays, and no significant break from overseas work.

Automatic Overseas Test 3: Full-Time Work Abroad

The original page's '35 hours per week' description is too simplistic. HMRC calculates whether an individual works full-time overseas by calculating net overseas hours over the relevant year. The calculation removes specified disregarded days, employment gaps and other permitted days from the reference period, then divides net overseas hours by the resulting number of weeks. An average of at least 35 hours is required under the statutory calculation.

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Actual hours worked are used rather than merely the hours stated in the employment contract.
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Days on which more than 3 hours are worked in the UK are identified as disregarded days for the overseas-hours calculation.
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The reference period is adjusted for certain employment gaps and other statutory exclusions.
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The final net overseas hours are divided by the number of weeks in the calculated reference period.
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The resulting average must be at least 35 hours.
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The individual must also spend fewer than 91 days in the UK and work more than 3 hours in the UK on fewer than 31 days.
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There must be no significant break from overseas work.

UK Day Counting: Midnight Rule, Transit and Deemed Days

For most SRT day-counting purposes, an individual has spent a day in the UK if they are present in the UK at the end of the day, normally midnight. The rule has important exceptions and modifications. Transit days can be treated differently, exceptional-circumstance days can be discounted for specified tests, and the separate deeming rule can count certain days when the individual was not physically in the UK at midnight.

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A normal UK day is generally counted where the individual is in the UK at midnight.
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Transit through the UK has special rules where the person is simply passing through.
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Exceptional circumstances can allow some days to be discounted for specified SRT tests.
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The deeming rule can add certain days where a person was present in the UK without being present at midnight.
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The deeming rule applies only if its own conditions are satisfied, including previous UK residence, UK ties and more than 30 qualifying days.
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The deeming rule does not apply to the fewer-than-91-day limit in the third automatic overseas test.

Sufficient Ties: The Correct 2026 UK Day/Tie Matrix

If none of the automatic overseas or UK tests determines residence, the sufficient-ties test is applied. The number of UK ties required depends on whether the individual was UK resident in one or more of the previous three tax years and how many days they spend in the UK during the current tax year.

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Family tie, accommodation tie, work tie and 90-day tie can be relevant.
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A country tie can also matter if the individual was UK resident in one or more of the preceding three tax years.
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More UK ties mean fewer UK days can be spent before UK residence arises.
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The original '16 to 89 days depending on ties' table was insufficient and should not be used as the calculation.
Previous UK ResidenceUK DaysMinimum UK Ties Needed
Resident in at least 1 of previous 3 tax years16 to 45 daysAt least 4 ties
Resident in at least 1 of previous 3 tax years46 to 90 daysAt least 3 ties
Resident in at least 1 of previous 3 tax years91 to 120 daysAt least 2 ties
Resident in at least 1 of previous 3 tax yearsOver 120 daysAt least 1 tie
Not resident in any previous 3 tax years46 to 90 daysAll 4 ties
Not resident in any previous 3 tax years91 to 120 daysAt least 3 ties
Not resident in any previous 3 tax yearsOver 120 daysAt least 2 ties

Automatic UK Tests Must Also Be Checked

An individual moving to Dubai can still be UK resident even when none of the automatic overseas tests applies. HMRC's automatic UK tests include the 183-day test, a UK-home test and a full-time-UK-work test. A UK home can therefore be critical even where the individual spends most of their working time in Dubai.

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183 or more UK days automatically makes the person UK resident.
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The UK-home test has its own 91-consecutive-day and 30-day presence conditions.
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The second automatic UK test can still apply where an overseas home exists if the statutory overseas-home conditions are met.
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The third automatic UK test examines a 365-day period of full-time UK work and the proportion of workdays spent working in the UK.
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A person moving abroad should therefore not rely solely on the 90-day figure.
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The actual residence result can only be determined after the full SRT is applied.

Temporary Non-Residence: Correct 2026 Rule

The temporary non-residence rules are separate from the ordinary SRT. HMRC's current rule treats an individual as temporarily non-resident where, broadly, their period of non-residence is 5 years or less and they had sole UK residence in at least 4 of the 7 tax years immediately before departure, subject to the detailed statutory conditions. If the rules apply, certain income and gains received during the temporary non-residence period can be charged in the year of return.

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The relevant historical residence test is 4 of the previous 7 tax years, not 4 of 5.
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The period of non-residence must be 5 years or less; exceeding 5 years by even one day takes the individual outside this specific temporary-non-residence period test.
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Certain capital gains can be brought into charge when the person returns.
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Certain pension payments, company distributions, chargeable event gains and other specified amounts can also be caught.
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Ordinary employment wages are not generally within the category described by HMRC as caught by the temporary-non-residence rules.
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Whole tax years or qualifying UK parts of split years treated as treaty non-resident can count toward the non-residence period.

UK-UAE Tax Treaty Residence Is Separate From the SRT

An individual can be UK resident under domestic SRT rules and also resident in the UAE under UAE domestic law. If both countries treat the person as resident, the UK-UAE Double Taxation Convention contains treaty residence tie-breaker rules. Article 4 looks first at permanent home, then centre of vital interests, then habitual abode and then nationality, with competent-authority mutual agreement if nationality does not resolve the issue.

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A UAE TRC does not automatically make a person non-UK resident under the SRT.
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Treaty residence is a separate determination from domestic UK residence.
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The UK-UAE DTA Article 4 uses permanent home as the first individual tie-breaker.
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If permanent homes exist in both states, the centre of vital interests is considered.
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If that cannot determine residence, habitual abode and then nationality are considered.
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The treaty has been modified by the Multilateral Instrument (MLI), so the current in-force/synthesised treaty text should be used.

UAE Tax Residency Certificate: 183 Days Is Not the Only Route

The original UAE TRC section is materially incomplete. The UAE FTA's August 2026 service card identifies multiple routes for a natural person applying for a Tax Residency Certificate. One route covers 183 or more days of physical presence in the UAE during a consecutive 12-month period. Another covers 90 to 182 days where additional evidence of UAE employment/business or a permanent place of residence is available. The FTA also has a primary-residence/centre-of-interests route with its own documentation.

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The FTA does not require every individual TRC applicant to prove 183 UAE days.
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The applicable route depends on the applicant's circumstances and the purpose of the certificate.
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The current August 2026 FTA service card says the requirements in that service card prevail if there is a discrepancy with older published materials.
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The TRC service is handled through the FTA's EmaraTax platform/UAEPass process.
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For natural persons without a Corporate Tax TRN, the FTA currently lists a fee for an electronic certificate.
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A TRC is documentary evidence of UAE tax-residence status; it should not be treated as conclusive proof of UK non-residence.
FTA TRC RouteCore Physical-Presence / Residence ConditionTypical Supporting Evidence
Case 1183 days or more in a consecutive 12-month periodEmirates ID or passport plus official UAE entry/exit report and required declaration
Case 290 to 182 days in a consecutive 12-month periodEmirates ID/passport, official entry/exit report plus UAE employment/business or permanent-place-of-residence evidence
Case 3Primary residence and centre of interests in UAE under the applicable rulesEmirates ID/passport, entry/exit report, financial/personal-interest evidence and primary-residence evidence

UAE Personal Tax Position and Corporate Tax Caveat

The UAE does not generally impose a federal personal income tax on an individual's employment salary, but 'Dubai is 0% tax' should not be used as a universal statement for every individual activity. UAE Corporate Tax can apply to a natural person carrying on a business or business activity where the statutory conditions and turnover threshold are met. Ordinary employment income and personal investment activity should therefore be distinguished from an individual conducting a taxable UAE business.

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Employment salary is not generally subject to UAE federal personal income tax.
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Personal investment income is distinct from carrying on a UAE business.
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A natural person conducting business in the UAE can fall within Corporate Tax where the statutory conditions are met.
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The UAE tax analysis should therefore identify whether the person's activity is employment, investment or business.
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The absence of UAE personal income tax does not determine UK SRT residence.

Moving to Dubai Does Not Automatically Eliminate UK Tax on UK Income

A person who becomes non-UK resident can still have UK tax liabilities on UK-source income and certain UK gains. Non-resident individuals may have UK Income Tax obligations on UK property income, UK employment duties and other UK-source income. UK residential property and land gains can also remain within UK CGT. The UK-UAE DTA may provide relief depending on the income category, but domestic UK non-residence is not the same as having no UK tax obligations.

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Non-residence does not mean all UK-source income becomes tax-free.
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UK employment duties can create UK taxation even where the employer is overseas or the individual lives in Dubai.
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UK property income can remain taxable in the UK.
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UK property and land gains can remain subject to UK CGT.
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The exact outcome depends on the income source, domestic law and the applicable treaty article.

Leaving the UK: P85, SA109 and Evidence

A person leaving the UK should notify HMRC using the route appropriate to their circumstances. GOV.UK states that someone who normally completes Self Assessment can report departure through the residence section SA109. A person leaving UK employment or otherwise qualifying may use P85. The forms do not determine residence themselves; they report information that HMRC uses alongside the statutory rules.

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P85 is relevant to people leaving the UK in circumstances covered by the GOV.UK guidance.
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People who normally file Self Assessment can report leaving through SA109.
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Travel records should be retained for every day spent in the UK.
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Evidence of overseas employment, UAE accommodation and residence should be retained.
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Evidence supporting UAE tax residence and any TRC should be retained where relevant.
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A person should not rely solely on a P85 or SA109 submission as proof that HMRC has accepted non-resident status.

Practical 2026 UK-to-Dubai Residence Workflow

A reliable UK-to-Dubai residence analysis should start with the UK SRT rather than with a UAE TRC. Calculate the individual's UK days, test the automatic overseas tests, test the automatic UK tests, and if necessary apply sufficient ties. Separately establish UAE tax residence and, if needed, obtain an FTA TRC. Finally test UK-source income, UK property gains, temporary non-residence, treaty residence and any applicable foreign-income regime.

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Step 1: identify the exact UK tax year of departure.
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Step 2: count UK days correctly using the midnight, transit, exceptional-circumstance and deeming rules.
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Step 3: test Automatic Overseas Test 1.
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Step 4: test Automatic Overseas Test 2.
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Step 5: test Automatic Overseas Test 3 using the statutory sufficient-hours calculation.
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Step 6: test the automatic UK tests.
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Step 7: if necessary, apply the sufficient-ties matrix.
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Step 8: determine whether split-year treatment may apply if the departure year is a split year.
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Step 9: determine UAE tax residence separately and select the correct FTA TRC route.
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Step 10: assess UK-source income and UK property/gains that remain taxable after departure.
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Step 11: test the temporary-non-residence rules based on the person's prior UK residence history and intended return date.
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Step 12: if both UK and UAE residence arise, apply the UK-UAE DTA residence article.
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Step 13: complete the relevant HMRC notifications/returns and retain documentary evidence.

Frequently Asked Questions (6)

There is no universal '90-day Dubai rule'. Under Automatic Overseas Test 3, you must spend fewer than 91 days in the UK, work for more than 3 hours in the UK on fewer than 31 days, and satisfy HMRC's full-time overseas-work calculation with no significant break. The sufficient-hours test is more detailed than simply working a 35-hour contractual week. If Test 3 does not apply, the automatic UK tests and sufficient-ties test must also be considered.

For the normal SRT day-counting rule, a day is generally treated as spent in the UK when you are present in the UK at the end of the day, normally midnight. Special rules apply to transit days, exceptional circumstances and the separate deeming rule. A person should therefore keep a precise travel log rather than relying only on flight dates.

The temporary non-residence rules can apply if the period of non-residence is 5 years or less and the individual had sole UK residence in at least 4 of the 7 tax years immediately before departure, subject to the detailed statutory conditions. If the rules apply, specified income and gains received during the temporary non-residence period can be taxed in the year of return. Ordinary employment wages are not generally within the HMRC category of amounts caught by this rule.

No. The UAE Federal Tax Authority's current August 2026 service card provides multiple routes for a natural-person TRC application. One route covers 183 days or more in a consecutive 12-month period. Another covers 90 to 182 days where additional evidence of UAE employment/business or a permanent place of residence is provided. The FTA also identifies a primary-residence and centre-of-interests route. The correct documents depend on the route.

The UAE does not generally impose federal personal income tax on an individual's employment salary. However, the statement 'Dubai has 0% tax' is too broad for every activity. A natural person conducting a UAE business can potentially be within UAE Corporate Tax if the statutory business and turnover conditions are met. In addition, UK tax can still apply if the person remains UK resident or receives taxable UK-source income.

The reporting route depends on your circumstances. GOV.UK states that someone who normally completes Self Assessment can report leaving through the residence section SA109. P85 can also be relevant for people leaving the UK in qualifying circumstances. Filing P85 or SA109 does not itself make you non-UK resident; HMRC determines residence under the statutory rules. You should retain travel, accommodation, employment and UAE-residence evidence.
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2026 TAX SNAPSHOT

Standard Personal Allowance
£12,570
Standard allowance; specialist and Scottish rules can differ.
England / Wales / Northern Ireland Basic-Rate Band
£37,700
£50,270 including the standard £12,570 Personal Allowance.
4-Year FIG Regime
Maximum 4 tax years
Available to qualifying new UK residents after at least 10 years of non-UK residence.
IHT Long-Term UK Residence
10 of previous 20 years
Overseas-asset exposure can continue for 3–10 years after leaving, depending on residence history.

Summary Takeaways & Checklist

  • Moving to Dubai does not automatically end UK tax residence; the full Statutory Residence Test must be applied for each UK tax year.
  • Automatic Overseas Test 3 requires full-time overseas work under HMRC's statutory sufficient-hours calculation, fewer than 91 UK days, fewer than 31 UK workdays and no significant break from overseas work.
  • The sufficient-ties matrix depends on previous UK residence and the number of UK days; it is not a single 16-to-89-day test.
  • A normal UK SRT day is generally counted when the individual is present at midnight, subject to transit, exceptional-circumstance and deeming rules.
  • Temporary non-residence generally uses a 5-years-or-less period together with UK residence in at least 4 of the previous 7 tax years.
  • A UAE Tax Residency Certificate is not an 183-day-only document; the FTA currently has multiple natural-person residence routes.
  • UK domestic non-residence and UAE treaty residence are different questions. The UK-UAE DTA has its own Article 4 tie-breaker rules.
  • UAE personal income tax on employment is generally absent, but a natural person conducting a UAE business can potentially fall within UAE Corporate Tax.
  • Becoming non-UK resident does not eliminate UK tax on all UK-source income or UK property gains.
  • P85 and SA109 report departure/residence information; they do not themselves create UK non-resident status.

Official References & Manuals

GOV.UK RDR3 Statutory Residence Test Guidance 2026HMRC Residence and FIG Regime Manual - Automatic Overseas TestsHMRC Third Automatic Overseas TestHMRC Working Full-Time Overseas CalculationHMRC SRT Day Counting RulesHMRC SRT Sufficient TiesHMRC Temporary Non-ResidenceGOV.UK Dual Residents 20262016 UK-UAE Double Taxation ConventionHMRC UAE Tax Treaty SummaryUAE Federal Tax Authority - Tax Residency CertificatesUAE FTA Tax Resident and Tax Residency Certificate Guide

Related HMRC Guides

HMRC Statutory Residence Test (SRT) Master GuideUK Expats Returning From Dubai Tax GuideHMRC SRT 90-Day Tie-Breaker Rule Guide