The UK's Statutory Residence Test (SRT) is one of the more clearly written individual residency tests in the world. It's a sliding scale of presence and ties that produces a determinate answer for almost any cross-border mover. The cases that fail in practice usually fail because someone miscounted ties or misread a day rather than because the rules are unclear.
In 2026 the SRT remains a stable backbone of UK tax planning.
The three layers
The SRT decides residence through:
- Automatic non-residence tests - if any apply, you are non-resident for the year.
- Automatic residence tests - if any apply (and no automatic non-residence test applies), you are resident.
- Sufficient ties test - a sliding-scale test combining days of presence with five specific ties (family, accommodation, work, 90-day, country tie).
Most cross-border movers spend their time in the third layer.
The five ties, briefly
- Family tie: spouse / civil partner / minor children resident in the UK
- Accommodation tie: a UK home available for use for a sustained period
- Work tie: working more than a defined number of days in the UK
- 90-day tie: spent more than 90 days in the UK in either of the two previous tax years
- Country tie: spent more time in the UK than in any other single country during the year (relevant for "leavers" only)
The number of ties combined with days of presence gives a determinate answer.
The "arriver" vs "leaver" distinction
The sliding-scale thresholds differ for arrivers and leavers. Someone arriving in the UK has a different days-per-ties grid than someone who was UK-resident in the prior three years. This matters more than people realise.
Split-year treatment
For people becoming UK-resident or ceasing to be UK-resident mid-year, split-year treatment can apply under specific conditions. This is the part of the SRT that most cross-border movers misunderstand - it is not automatic, and the conditions for split-year vary by scenario.
The non-dom / remittance regime in 2026
The historic UK non-dom remittance basis has been reformed materially. The 2026 position is materially different from the pre-reform regime, and the relevant current legislation must be consulted for any case relying on it.
Any planning that assumes the historic remittance basis continues unchanged is out of date. Any planning that assumes "non-dom" still means what it meant a decade ago is wrong.
Where people miscount
- Transit days: days where you arrive late and leave early can sometimes count for SRT purposes; the rules need reading.
- Exceptional circumstances: there is a narrow allowance for exceptional days, but it's narrower than people imagine.
- Family tie: a separation that's not legally formalised can still be a family tie for SRT purposes.
- Accommodation tie: a UK property used by you for one night in the year can be enough.
How we coordinate this
For every UK case we model the SRT against the specific calendar years involved - both the move year and the surrounding years. We document the ties expected, the presence plan, and the planned filings. We don't treat the SRT as something to figure out at the end of the year; we plan against it from the start.