This is the return-side bookend to our 12-month pre-departure checklist. Where the departure page actioned the operational machinery of leaving (P85, NRL1, SRT planning for the departure year, sell-or-hold modelling on the UK home), this page actions the operational machinery of returning. The Statutory Residence Test runs separately for each tax year, so re-establishing UK residence is its own arithmetic exercise; split-year Cases 4, 6 and 8 handle the mid-year case; section 10A TCGA 1992 surfaces as a recapture event for anyone returning within 5 complete tax years of departure; the NRL scheme is wound down with the agent on the other side; and the residence-based April 2025 IHT regime and the 4-year FIG window both come into play for the return-arc planning.

The return is not a mirror image of the departure. The departure page emphasised pre-emption (set up NRL1, model the sell-or-hold, time the disposals). The return page emphasises closure of one regime (NRL ends, the s.10A clock resolves) and entry into another (UK CGT on post-arrival disposals, residence-based IHT, FIG if you qualify). One anonymised scenario (Naomi, a UK landlord returning after a 5.5-year Singapore secondment in April 2027 with portfolio additions made while abroad) runs through the figures.

12 months before return: planning levers worth pulling

The decisions that materially change the return-year tax outcome are taken before re-arrival, not on the day of landing.

  • Time the SRT split point. Where the return is mid-year, the trigger for the relevant split-year case (Case 4 ending of overseas home, Case 6 ending of full-time overseas work, Case 8 starting to have a UK home) determines whether the year is taxed as a split year or as a full UK-resident year. Choosing to retain the overseas home for an extra month, for example, can push the split date later and remove an unwanted UK month from arising-basis taxation.
  • Time disposals against the s.10A clock. If you are within 5 complete tax years of departure, gains realised during non-residence on assets owned at departure are deemed to arise in your year of return. Holding a disposal until the 6th tax year of non-residence (which crosses the 5-year-or-less threshold to over-5-year) removes the gain from s.10A scope. The 5-year recapture page walks the mechanic in detail.
  • Pre-arrival disposals. A UK land disposal completed while still non-resident is in NRCGT (60-day clock, 18% / 24% residential rates with rebasing default). A disposal completed after re-arrival is in normal UK CGT (same rates but the AEA applies and the gain enters the SA pool, with the 60-day clock still running). The economics are usually similar; the operational difference is the residency status at completion.
  • Pre-arrival foreign-asset cleaning for FIG. If you qualify for FIG (10+ years clean non-UK residence preceding return), assess what foreign income and gains can usefully be accelerated into the first 4 years of UK residence. The window is fixed and the personal-allowance surrender cost runs annually.
  • Pre-arrival UK home arrangements. Acquiring a UK home on (or shortly before) the return date can trigger Case 8 split-year treatment. Where the UK home is bought during non-residence with a view to returning, the 2% non-resident SDLT surcharge is in play but refundable if UK residence is established within 12 months of completion.

The SRT in your return year

The Statutory Residence Test under FA 2013 Schedule 45 determines residence for each tax year. The cascade for the return year:

Automatic UK tests (any one met makes you UK-resident). 183 or more UK days in the year (almost always met by a full-time UK return); only home in UK for at least 91 consecutive days with 30+ days in that period in the tax year (met by anyone re-establishing a single UK base); full-time UK work for the year (75% UK workdays in a 365-day period spanning the year). A full-time UK return typically passes the first automatic test by Christmas.

Automatic overseas tests (failing any UK test, any overseas test met keeps you non-UK resident). Under 16 UK days (where UK-resident in any of the preceding 3 years); under 46 UK days (where not UK-resident in any of the preceding 3 years); full-time overseas work (35-hour week, ≤30 UK workdays, ≤90 UK days). For a returner these will not be met because the return brings UK days well above the thresholds.

Sufficient ties test. Where no automatic test is met, the test runs on UK ties (family, accommodation, work, 90-day, country) against day-count. Mid-year returners often pass an automatic UK test before sufficient ties needs to run.

The companion SRT decision tree walks the cascade in full with landlord scenarios. The point for the return year is that residence is rarely ambiguous when a person genuinely returns to live in the UK; ambiguity arises only at the margins of mid-year returns with retained overseas ties.

Split-year arrival: Cases 4, 6 and 8

Where the SRT places you as UK-resident for the year but you arrived partway through, split-year treatment may apply. Three cases cover the arrival side.

Case 4 (starting to have only a UK home). Applies where you cease to have any overseas home during the year and the UK is the only home from the relevant date. The split date is the day you start to have only a UK home (typically the day the overseas lease ends or the overseas home is sold). The condition includes a minimum overseas-residence period in the prior year and a minimum UK presence after the split.

Case 6 (ceasing full-time overseas work). Applies where you return from a job that met the third automatic overseas test (35-hour week, no significant break) and that job ends in the year. The split date is the day the overseas job ends. This is the most common case for typical 3-to-7-year overseas secondments.

Case 8 (starting to have a UK home). Applies where you start to have a UK home in the year (purchase or move into a UK home that was not previously yours) and meet the relevant conditions. The split date is the day you start to have the UK home.

Where multiple cases could apply, FA 2013 Sch 45 paras 53-55 set the priority order. Case 1 (departure) and Case 2 (partner of Case 1) are leaving-side; Cases 3-8 include arrival cases and need careful sequencing. The split-year cases page works through each case with landlord-specific examples and the priority rules.

The s.10A 5-year recapture surfacing on the return-year return

Section 10A TCGA 1992 deems gains realised during a period of temporary non-residence to arise in the year of return. The test for an individual:

  • The individual was UK tax resident in at least 4 of the 7 tax years immediately preceding the year of departure (the "4 of 7" condition).
  • The individual's period of non-UK residence is 5 years or less (verified against HMRC CG26540, 2026-05-22).
  • The gain was realised on an asset owned at departure and disposed during the non-residence period.

The deemed-accrual mechanic: gains caught by s.10A are treated as arising in the return year and reported on the SA108 (capital gains supplement) for that year, taxable at the return-year CGT rates. Indexation, reliefs and AEA are computed on the deemed-arising basis.

What s.10A primarily catches. Non-UK situs assets (foreign property, foreign shares, foreign bonds) disposed during non-residence. UK land is already in NRCGT (residential from 6 April 2015, non-residential and indirect from 6 April 2019), so the NRCGT-rebased post-2015 / post-2019 portion of the gain is settled at the time of disposal. The s.10A piece on UK land is the pre-rebasing portion (pre-2015 for residential, pre-2019 for non-residential) that NRCGT did not catch.

Example arithmetic. A residential property acquired in 2010 for £180,000, with 5 April 2015 rebased value £290,000, sold in 2027/28 (during a 4.5-year non-residence) for £380,000. NRCGT at the time of disposal: gain £380,000 - £290,000 = £90,000 at 24% = £21,600 (less AEA). On return to the UK in 2028/29 (within 5 complete tax years of departure), s.10A deems the pre-rebasing portion (£290,000 - £180,000 = £110,000) to arise in 2028/29 at the return-year residential rate of 24%, adding £26,400 of UK CGT on the 2028/29 SA. The pre-rebasing portion is the avoidable cost; deferring the disposal to the 6th tax year of non-residence (or longer) would have removed s.10A from the picture.

NRL1 cancellation and the agent switchover

The Non-Resident Landlord scheme applies only to non-residents. From the date of resumed UK residence (or the split-year date) the scheme ceases to apply, with operational obligations on both the landlord and the letting agent.

Landlord side. Notify HMRC that UK residence has resumed. The notification can be by letter or via the agent acting under authority. HMRC withdraws the NRL approval; the formal withdrawal notice is the trigger for the agent to stop withholding. Until the notice is received, the agent must continue to operate the NRL scheme even if the landlord has already moved back to the UK.

Agent side. The agent must operate NRL withholding from the start of the quarter following any return that has not yet been notified to HMRC. Once HMRC's withdrawal notice is received, the agent switches to gross payment from the next pay event. The annual NRL6 certificate for the final NRL year is still due by 5 July following the relevant tax year, covering the period up to the agent's switchover date. The agent's NRL2 quarterly returns continue until the switchover.

The companion agent-side NRL mechanics page covers the agent's quarterly machinery; the NRL pillar covers the scheme overview. From the date of switchover, UK rental income pays gross to the landlord and is reported on the standard SA105 (UK property pages).

UK CGT clock restart and post-arrival disposals

Once UK residence is re-established (or from the split-year date), UK property disposals fall back into the normal UK CGT regime. The mechanical changes:

  • NRCGT ceases to apply to your disposals (it only operates on non-residents). The 60-day reporting and payment clock continues to apply to UK residents disposing of UK residential property (the 60-day clock was extended from the UK-resident 30-day clock in October 2021 to align with the non-resident clock).
  • The Annual Exempt Amount (£3,000 in 2026/27) applies in full to UK residents.
  • Pre-rebasing portions of pre-2015 (residential) or pre-2019 (non-residential) UK land gains are back in scope for disposal-year CGT (the rebasing was a non-resident-only carve-out; on return the full gain is in scope at the standard rates).
  • Indexation, principal private residence relief, lettings relief (where still available) and other reliefs apply on normal UK-resident lines.

For a returner planning a disposal of a long-held UK rental that has appreciated materially, the timing decision (pre-arrival NRCGT versus post-arrival UK CGT) is usually dominated by the s.10A clock: disposals during the 5-year window are recaptured into the return year anyway, so the pre / post-arrival question for residential land usually reduces to small operational differences. For non-residential land or for properties acquired post-rebasing date, the question becomes more material.

FIG eligibility for the long-duration returner

The 4-year Foreign Income and Gains regime applies to qualifying new arrivals (including returners) who have been non-UK tax resident in each of the 10 tax years immediately preceding the first qualifying year. The eligibility test is strict: a single UK-resident year in the 10-year lookback disqualifies.

Practical groups:

  • 11+ year emigration with no UK residence in any lookback year: eligible. FIG shields foreign income and gains for 4 years from re-arrival, with the personal-allowance surrender cost running annually.
  • 5-10 year emigration: not eligible. The 10-year lookback is not clean. FIG returns to the table only once 10 consecutive non-residence years accrue (which requires a fresh emigration of similar duration).
  • Under-5-year emigration: not eligible (and within s.10A scope on top).

For an eligible returner with material foreign income, the FIG election year-by-year decision tracks the same cost-benefit as any inbound investor: the personal-allowance and AEA surrender against the foreign-income shield. The non-dom reform / FIG page covers the mechanics in full. UK rental income on UK property is outside FIG regardless of FIG status; FIG covers only foreign source.

The residence-based IHT regime on return

From 6 April 2025 IHT scope on worldwide assets is based on long-term UK residence (LTR), with LTR established by 10 of the preceding 20 tax years of UK residence (HMRC also recognises the 10-consecutive-years route as a second qualifying path). The return scenarios:

  • Returner who was previously LTR and left for a short window: retains LTR status during a tail period (3 to 10 years depending on years previously resident). Worldwide assets remain in UK IHT scope during the tail. The departure did not shed UK IHT on worldwide assets.
  • Returner who was previously LTR but left for a longer window (clearing the tail): re-arrives as a fresh-start individual for IHT purposes, with the 10-of-20 clock running from re-arrival. Worldwide assets are outside UK IHT until the new LTR test is met.
  • Returner who was never LTR (first emigration broke the chain before 10 years accrued): re-arrival as a fresh-start individual; 10-of-20 clock running.

UK situs assets (including UK residential property held directly and Schedule A1 IHTA 1984 look-through structures) are always within UK IHT regardless of LTR status. The return-arc IHT planning is therefore primarily about whether worldwide assets are pulled back into UK IHT immediately (returning LTR tail), gradually (clock running from re-arrival), or not at all in the near term (long pre-emigration window then short return).

Worked example: Naomi, 5.5-year Singapore secondment returning April 2027

Naomi, 44, UK national, finance director. She left the UK on 1 October 2021 for a Singapore posting on a 5-year contract that was extended by 6 months. She returns on 1 April 2027 to take up a UK consultancy role starting 7 April 2027. She owned two London BTLs at departure (acquired 2014 and 2019) and bought one Singapore condo in 2022 during the secondment. Combined UK rental £36,000 gross / £4,000 net after section 24; Singapore rental SGD 60,000 / approximately £35,000 net; UK total CGT-base portfolio: London A (2014, base £280,000, sold 2025 at £400,000 while non-resident), London B (2019, base £340,000, current value £390,000, retained), Singapore condo (2022, base SGD 1,400,000 / approximately £820,000, current value SGD 1,650,000 / approximately £965,000, retained).

SRT 2027/28 (year of return). Naomi arrives 1 April 2027 (start of UK 2027/28 tax year). She is UK-resident for 2027/28 from day 1; no split year needed. Her SRT outcome is the first automatic UK test (183 days easily met). Her 5.5-year non-residence period is more than 5 complete tax years; s.10A does not apply.

Wait. The 5-year test counts on the basis of complete tax years of non-residence. Naomi was non-resident 2021/22 (partial), 2022/23, 2023/24, 2024/25, 2025/26, 2026/27 (the full year because she returns on 1 April 2027, the day before the 2027/28 tax year starts). Five complete tax years (2022/23 to 2026/27). The s.10A test "5 years or less" includes 5 years exactly; her position is borderline. The clean reading per HMRC CG26540 is that the period is "more than 5 years" only when it strictly exceeds 5 complete tax years; 5 complete years exactly is within s.10A. Naomi's 2025 disposal of London A during non-residence falls within s.10A scope.

s.10A recapture on the 2027/28 return. London A disposal: NRCGT at the time of disposal (2025/26) on the post-2015 portion: gain £400,000 - £280,000 = £120,000, but the 5 April 2015 rebasing default applied. London A was bought in 2014 for £280,000, with 5 April 2015 rebased value (say) £290,000. NRCGT gain on post-2015 portion: £400,000 - £290,000 = £110,000 at 24% (assuming higher-rate rate band): £26,400 (less AEA). On return in 2027/28, s.10A deems the pre-rebasing portion (£290,000 - £280,000 = £10,000) to arise in 2027/28 at 24%: £2,400 of UK CGT added to the 2027/28 return. The pre-rebasing portion is small because the property was bought just before NRCGT extended to residential, so the s.10A overlay is modest.

Singapore condo disposal exposure. Naomi has not disposed of the Singapore condo. If she sells it after return, the disposal is in normal UK CGT at the time of sale (she is UK-resident), with the full historic gain in scope. There is no Singapore-CGT-rebasing equivalent on return; the asset enters UK CGT scope with its original acquisition cost. If she sells the condo in 2028/29 for SGD 1,750,000 (approximately £1,025,000), her gain is approximately £205,000 (£1,025,000 - £820,000) at 24%: £49,200 of UK CGT (less AEA, less Singapore CGT credit which is zero because Singapore has no CGT on personal property disposals). The CGT exposure on the Singapore asset was largely accrued during non-residence but is taxed on UK-resident disposal.

FIG eligibility. Naomi has been non-UK-resident for only 5 complete tax years (2022/23 to 2026/27); the 10-year FIG lookback is not clean. She is not eligible for FIG. Her Singapore rental income for 2027/28 onwards is taxable on the arising basis in the UK, with foreign tax credit for Singapore tax paid under the UK-Singapore DTA.

NRL1 cancellation. Naomi notifies HMRC on her return date; HMRC withdraws NRL approval; her letting agent (managing London B during non-residence) switches to gross payment from approximately mid-May 2027 (allowing 6 weeks for processing). She files her final NRL-year self-assessment for 2026/27 with the NRL6 certificate.

IHT regime on return. Naomi was previously UK-resident for many years pre-departure (assume 20+ years from 1999 to 2021). She was LTR pre-departure under the new regime (she meets 10-of-20 from her pre-2021 history). On departure, the LTR tail kicks in: between 3 and 10 years depending on her exact residence years. With 22 years of UK residence pre-departure, the tail is the full 10 years; she remains within worldwide-asset IHT scope for 10 years after departure (i.e. until 2031). Her 5.5-year non-residence period sits entirely within the LTR tail; her worldwide assets (Singapore condo, any foreign investments) were in UK IHT scope throughout. On return in April 2027, she is back to active LTR status and stays so going forward.

Common return-pathway misconceptions corrected

"I was non-resident for 5 years so s.10A doesn't apply." Wrong. The test is "5 years or less" of non-residence, which includes exactly 5 complete tax years (verified HMRC CG26540, 2026-05-22). The clean break from s.10A requires more than 5 complete tax years (typically 6 complete tax years to be safely outside).

"My UK rental income is exempt for 4 years under FIG on return." Wrong on two counts. First, UK rental income on UK property is UK-source under s.264 ITTOIA 2005, never in FIG scope. Second, FIG requires 10+ years of clean non-UK residence preceding return; a 5-to-10-year emigration does not qualify.

"The NRL scheme ends automatically on the day I return." Wrong in operational terms. The scheme ceases to apply legally from the date of resumed residence, but the letting agent must continue to withhold until HMRC's formal withdrawal notice is received. Notify HMRC promptly and brief the agent in advance to switch the moment the notice lands.

"Disposals I made while non-resident are settled; nothing further is due on return." Sometimes wrong. The 60-day NRCGT returns settle the post-rebasing portion of UK residential land gains (post-2015) and UK non-residential land gains (post-2019). The pre-rebasing portion is recaptured under s.10A on the return-year SA where the 4-of-7 prior-residence and 5-year non-residence conditions are met. Long-held UK property disposed during a short overseas posting is the s.10A sweet spot.

"I bought UK property abroad and paid the 2% non-resident SDLT surcharge; that's done and dusted." Sometimes wrong. The Schedule 9A FA 2003 surcharge is refundable if the buyer becomes UK tax resident within 12 months of completion (183 UK days in any continuous 365-day period including completion day). Returners who completed a UK purchase shortly before their return often qualify; file the SDLT amendment within 12 months of the SDLT return filing date.

"My departure already established my IHT non-residence; I'm only in UK IHT for UK situs." Often wrong from 6 April 2025. The residence-based IHT regime brought in the LTR concept: anyone who was a long-term UK resident (10 of 20 years) before departure retains LTR status during a tail period (3-10 years depending on prior residence). Worldwide assets remained in UK IHT during the tail; only after the tail clears does the LTR status fall away. The companion April 2025 IHT residence test page covers the mechanics.

The arc closes

The return to the UK closes the arc that the 12-month pre-departure checklist opened. The mechanical close-out items (NRL cancellation, SA registration if lapsed, split-year case analysis on the SA109, s.10A recapture computation on the SA108 where applicable, FIG eligibility verification if 10+ years of non-residence accrued) are predictable and operational. The substantive planning levers (timing the SRT split point, sequencing disposals around the s.10A clock, modelling FIG election cost-benefit for the eligible long-duration returner, mapping IHT scope under the residence-based regime) are where the year of return tax outcome is genuinely shaped.

For returners within 5 complete tax years of departure, s.10A is the dominant question. For returners after 10+ clean years, FIG is the structural opportunity. For returners between 5 and 10 years, the picture is operational close-out with no FIG cover and no s.10A exposure: the cleanest return-arc on the income-tax and CGT sides, with IHT then depending on the prior-residence-and-tail history. Each band needs its own planning emphasis.