UK-U.S. Tax Guide: What You Need to Know When Leaving the UK

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If you’re planning a move from the UK to the US, understanding your UK tax position is an important step in making the transition as smooth as possible.

Whether you’re taking up employment, running a business, or managing investments, this guide—written by UK/US tax expert, Jordan Onraet-Wells, founder of Horizon UK Tax Solutions—outlines the key things to consider when it comes to your UK tax affairs.

UK residency – the starting point

Your UK tax residency status affects what income HMRC can tax. The Statutory Residence Test (SRT) is used to determine whether you are considered a UK resident for tax purposes. It takes into account the number of days you spend in the UK, your ties to the country, and other factors.

If you’re leaving the UK, you may qualify as non-resident, but only if certain conditions are met. In the year you leave, split-year treatment may apply. This allows only part of your income to be taxed in the UK, but it must be claimed on your Self Assessment return.

Do I still need to file a UK tax return after I leave?

You may still have UK tax obligations even after you’ve left the country. A UK return is still required if you:

  • Receive UK income such as rent, pensions, dividends, or employment income
  • Own property or assets in the UK
  • Hold shares or interests in a UK business
  • Want to claim split-year treatment or confirm your non-resident status

In these cases, you’ll usually need to complete the SA109 ‘Residence’ pages as part of your return.

Employed and moving to the US?

If you’re moving to the US for a job, your UK employment income might still be partially taxable depending on when you leave and your UK residency status. If you stop working partway through the tax year, you may be eligible to claim split-year treatment.

Your UK employer should issue a P45 — this will help with finalising your tax position. In some cases, you may be due a refund if too much PAYE tax was withheld.

Self-employed or running a business?

If you’re self-employed, UK tax continues to apply to your business income up until the point you become non-resident. If you carry on working for UK clients or receive UK-sourced income after leaving, this may still be taxable in the UK.

In the US, self-employment tax also applies, so early planning is key to avoid double taxation and unexpected liabilities.

If you own or run a UK limited company, you’ll still be subject to UK corporation tax and other obligations if the business is effectively managed from the UK. Cross-border operations can create ‘permanent establishment’ risks, so careful structuring and clear documentation are essential.

Renting out your UK home

If you plan to rent out your UK property after moving abroad, you’ll need to:

  • Register under the Non-Resident Landlord Scheme (NRLS)
  • Continue filing UK Self Assessment returns showing rental income and expenses
  • Claim US foreign tax credits to avoid double tax on UK rental income

UK pensions and trusts – what to watch for

Pensions
UK private pensions are usually only taxed in the US under the UK–US tax treaty. UK government pensions remain taxable in the UK.
To stop UK tax being withheld, you can submit form DT/Individual to HMRC.

Trusts
UK trusts can still be within scope for UK tax even after you become non-resident. This includes income tax and inheritance tax risks. If you created a trust while still UK domiciled, or receive distributions, you may have tax and reporting duties in both countries.

The UK–US tax treaty

The tax treaty between the UK and US helps reduce the risk of double taxation. It covers areas such as employment income, dividends, interest, royalties, capital gains, pensions, and social security.

To benefit from the treaty, you must actively claim relief through the correct forms with both HMRC and the IRS.


How Horizon UK Tax Solutions can help:

  • Understand and manage your UK residency and split-year claims
  • File UK tax returns as a resident or non-resident
  • Comply with the Non-Resident Landlord Scheme
  • Make UK–US tax treaty claims and manage pension reporting
  • Structure your business effectively across borders
  • Navigate trust reporting and inheritance tax planning

We’ll keep things simple, clear, and practical — so you can stay compliant and move forward with confidence.

Want to learn more? Email Jordan at jordanonraet-wells@horizonukts.com and take control of your UK/US tax affairs.

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