Heading to the UK? Here’s How to Avoid Being Tax Resident in Two Countries

Written by Greg Hanton. Greg is co-founder of Joy Pilot, No Worries Accounting, No Worries Red Umbrella, and Capital City Accountancy. He has over two decades of experience in providing tax and accounting support to contractors, especially those working in the UK. Greg holds a BE (Hons) in Chemical & Process Engineering from the University of Canterbury and a BSc in Chemistry from the University of Otago. He is also a Chartered Accountant (ACCA), member of AAT, and a Chartered Engineer (IChemE). With a passion for innovation and client-focused solutions, Greg continues to lead the charge in transforming the accounting landscape. See more on LinkedIn.

Originally posted on: 17 November 2025
Updated on: 13 January 2026

Introduction

If you’re a Kiwi heading to the UK, it’s easy to assume your tax residency switches the moment your plane takes off. One day you’re a New Zealand taxpayer, the next you’re settling into London life, and everything simply transfers across. Unfortunately, it doesn’t work quite that neatly in some cases.

We speak with a lot of UK-based Kiwis each month, and for the recently arrived ones, the conversation almost always starts with tax residency, because that sets the tone for the rest of the discussion. There is a huge amount of confusion about this. Some people think they can just choose their tax residency, some think the IRD can decide it for them, and some think that if they are in the UK and pay NZ tax on any NZ income, then they’re all sorted.

Now, in most situations, everything works out fine in the end, but there are some where it doesn’t, and this is where a little planning can make a big difference.

There are also a few who try to purposefully remain both NZ and UK tax resident, thinking it simplifies things or keeps them on the lowest overall tax rates. The opposite is true. Being tax resident in both the UK and NZ gives you the worst of both worlds, where your income can be taxed at the highest possible rate across two systems.

In reality, there can be a lot of grey area in the year you move. New Zealand has its own rules around tax residency (with a recently updated Tax residence Interpretation Statement – hurray!) when leaving, including the 325 day rule and the less understood permanent place of abode test. The UK has a completely different system, the Statutory Residence Test, which looks at days, ties, work patterns, and even where your family lives. It’s entirely possible to meet both sets of rules at the same time.

This blog breaks everything down in plain English. We’ll look at how NZ and UK tax residency rules actually work, why people fall into dual residency without meaning to, how the double tax agreement fixes most of the problem, and the practical steps you can take to avoid unnecessary tax headaches when you make the move.

How NZ Tax Residency Works When You Leave New Zealand

Most people assume that once they move overseas and stop spending time in New Zealand, their tax residency simply ends. In reality, New Zealand’s rules about leaving are a bit more nuanced, and understanding them upfront can help avoid confusion later.

The two key concepts to understand

When you leave New Zealand, two parts of the tax residency rules become important. One is a day count, the other talks about where you “habitually reside”.

The 325 day rule for ceasing residency

To stop being a New Zealand tax resident under the day count rule, you need to be absent from New Zealand for more than 325 days in total in any 12-month period, and you must not have a permanent place of abode in New Zealand.

The days of absence do not need to be consecutive, and short trips back do not reset everything to zero, but they do reduce the number of days of absence you can count in that 12-month window, which can delay the date you become non-resident.

Inland Revenue effectively looks for the first day in that 12-month stretch where you are both absent and no longer have a permanent place of abode – that’s the day your non-residence is treated as starting.

Permanent place of abode (PPA)

This is the big one, and the reason some people remain NZ resident without realising it.

PPA is all about whether New Zealand still looks and feels like your long-term home. It is not simply whether you own property in New Zealand. Instead, Inland Revenue looks at your wider connections, including things like:

  • whether you have a house in New Zealand that is genuinely available for you to live in
  • whether family members remain in New Zealand
  • how your time is actually spent between NZ and overseas
  • where your economic and social ties sit, for example banking, memberships and community links

Put simply, you can be outside New Zealand for long stretches, but if your home base is still there and your ties remain strong, you can continue to be New Zealand tax resident.

This is why selling or genuinely long-term renting out a property, moving your belongings, and shifting your life offshore usually creates a clean departure, while keeping a home available “just in case” often does not.

A pure investment property that you’ve never lived in usually won’t count as a PPA, but a family home can still be a PPA even if it’s rented out while you’re overseas, if you still habitually use it as your base.

image from the marina of down town auckland new zealand

Common Kiwi departure scenarios

Here are some of the situations we see most often when talking with people who have recently moved to the UK.

Keeping the family home because you might come back
You move to the UK, but keep the NZ house empty or only lightly used because you want the option to return. If that property is effectively still your base in New Zealand, PPA can continue, even if you are out of the country for long periods.

A partner or children staying behind
If your partner or children remain in New Zealand for work or school, while you head to the UK first, that is usually a strong ongoing tie unless the move offshore is clearly permanent and the family home is being sold or genuinely given up. Inland Revenue looks at the whole picture – what you intend to do with the property and where you actually base your life – not just where your family sleeps for a few extra months.

Short-term or intermittent use of the property
Listing a house on Airbnb for gaps between your own trips back, or using it for holidays, does not always break the PPA link. Inland Revenue is more interested in whether the dwelling is available to you as a home over time, rather than exactly how many weeks it is rented out. Short-term holiday or Airbnb use often isn’t enough, on its own, to break PPA – Inland Revenue is far more interested in whether you still treat the place as your home base over time.

Selling your home or renting it out long term
This is usually where things are more straightforward. Once the home is off the table as a realistic place for you to live, and your day counts and other ties support the move offshore, it becomes much easier to argue that your PPA in New Zealand has ended and, in time, that your residency has ceased.

Why some people unintentionally stay NZ resident

Most cases of unplanned continued residency come from misunderstandings rather than deliberate choices. The main reasons tend to be:

Not realising PPA overrides the day count
Many people focus on the 325 day rule and assume that once they hit it, residency ends automatically. In reality, PPA is considered first. If Inland Revenue thinks your permanent place of abode is still in New Zealand, residency can continue even after long periods overseas.

Leaving in a hurry
Sometimes a move is quick or unplanned, and people do not stop to think about the position of their home, family and other ties before jumping on a plane. By the time they look at it properly, they have already created an overlap.

Assuming that not physically living in NZ is enough
It feels intuitive that if you are not “living” in a country anymore, you cannot be resident there. New Zealand’s rules do not quite work that way. They focus on whether New Zealand still looks like home on paper and in practice, rather than just where you happen to be sleeping right now.

How UK Tax Residency Works When You Arrive in the UK

When you land in the UK, your UK tax residency is simply determined by the UK’s Statutory Residence Test. The rules look technical on paper, but the basic idea is straightforward. The UK cares about where you actually live, work and spend your time.

The Statutory Residence Test (SRT) made simple

The SRT looks at two things:

  • how many days you spend in the UK in a tax year, and
  • how many ties you have to the UK, such as work, accommodation and family.

Once your combination of days and ties crosses certain thresholds, you are treated as UK tax resident for that tax year.

For a Kiwi arriving in the UK, the most relevant parts are usually:

Full time work in the UK
If you come to the UK and start working full time here, you will usually become UK resident immediately, even if you have not spent 183 days in the country. The pattern of your work and where it is physically carried out is a key factor.

183 days in the UK
If you spend 183 days or more in the UK in a tax year, you will normally be UK resident for that year. This is the simple headline rule many people know, but it is only part of the picture. For someone who moves early in the tax year, this threshold can be reached without thinking about it.

Accommodation and family ties
The UK also looks at whether:

  • you have a home or other accommodation available to you in the UK, and
  • your spouse or partner, and in some cases children, are living here with you.

These “ties” matter most when your day count is in the middle ground. The fewer days you are in the UK, the more ties you need for residency to begin. The more days you are in the UK, the fewer ties are needed.

Residency can begin earlier than you might expect
The key point is that UK residency does not wait politely until you feel settled. For many Kiwis, the combination of starting work, signing a tenancy and spending most of their time in the UK means UK tax residency can effectively begin on the day they arrive in the UK.

Split year treatment

By default, if you are UK resident for a tax year, you are treated as resident from the first day of that tax year (06 April). It seems a bit odd to most people – its means that if you arrive in the UK on 01 Dec 2025 and become UK tax resident, your tax residency is then back-dated to 06 April 2025. It’s a potential nightmare. Fortunately, the UK offers split year treatment. In a lot of cases for our clients, the UK allows a tax year to be split into:

  • non-resident part at the start of the year, and
  • resident part from the point you effectively “arrive” for tax purposes.

This can help a newly arrived Kiwi, because it means only income and gains arising in the UK part of the year are treated as within the UK net.

Real world examples for Kiwis arriving

A few simple examples help show how this plays out in practice.

Moving in February for a job starting 1 March
You arrive in the UK in February, towards the end of the UK tax year, and start full time work on 1 March. Even though you are only in the country for a few weeks before 5 April, the combination of full-time work and your intention to live here can mean you become UK resident from a specific date, with split year treatment available in many cases.

Arriving late in the UK tax year and triggering residency earlier than expected
You land in the UK in January, spend almost all your time here, and sign a 12-month tenancy. You might assume you will only become resident from the following tax year, but your day count and ties could mean residency starts part way through the current tax year instead.

Remote working for a New Zealand employer while living full time in the UK
You keep your New Zealand job, are paid into a New Zealand bank account and log in on NZ hours, but you are physically living in a flat in London. For SRT purposes, the fact that you are doing that work from the UK, and spending most of your days here with accommodation available, can mean you are UK resident, even though nothing has changed on the New Zealand side.

aerial view of london with sun setting

How Dual Residency Can Happen (Even Though It Is Uncommon)

By this point you might be thinking, “Surely the systems talk to each other and figure this out in the background.” Unfortunately they do not. New Zealand and the UK each have their own tax residency rules, and they apply them independently.

A simple explanation of dual residency

For New Zealand, the key questions when you leave are:

  • do you still have a permanent place of abode in NZ, and
  • have you been absent for more than 325 days in a 12 month period.

For the UK, the focus when you arrive is:

  • how many days you spend in the UK in a tax year, and
  • how many ties you have here, such as work, accommodation and family.

In some situations, especially in the year you leave NZ and arrive in the UK, it is possible to meet both sets of rules at the same time. New Zealand can still see you as having a base there, while the UK sees you living and working there on a settled basis.

Most people do not end up in this position. They either clearly wrap up their New Zealand life and move, or they clearly treat the UK as a short-term stop. However, for the small group who sit in between, the fact patterns start to look very similar.

The typical fact patterns where it can occur

Although every case turns on its own facts, the dual residency risk tends to crop up when the following are true.

Keeping a family home in NZ that remains genuinely available
You have a house in New Zealand that you have used as your main home and it is still realistically available for you to live in, even if it is rented out part of the time. From a New Zealand perspective, that can still look like a permanent place of abode.

Lots of back and forth travel in the first year
You spend long stretches in the UK, but also return to New Zealand several times. Day counts for both systems start to creep up, and it becomes harder to say that you habitually reside only in one place.

Why dual residency is mostly a paperwork and planning problem

The good news is that even if you are technically resident in both countries under their domestic rules, the double tax agreement between New Zealand and the UK will usually decide which country gets first call on taxing your income, and will stop you being taxed twice on the same income if things are filed correctly.

In other words, dual residency is not usually about paying tax twice. It is about:

  • having to apply treaty rules to work out which country is treated as your main state of residence,
  • getting the right income in the right box on the right return in each country, and
  • making sure relief is claimed properly where one country is giving way to the other.

The real risk is incorrect filings or optimistic assumptions, for example assuming you have ceased NZ residency when you have not, or assuming the UK cannot tax certain income because it is “New Zealand income”. That is where unexpected bills and penalties can arise.

There is also a quieter, but very real, “worst of both worlds” risk. Even when the treaty works as intended, you can end up paying tax at the higher of the two countries’ rates on certain types of income, once foreign tax credits are taken into account. You are not taxed twice on the same dollar, but over the year you can still find that UK rules bite on some income, NZ rules bite on other income, and you effectively climb to the top end of whichever system is harsher in each area.

So the problem with dual residency is less “double tax”, and more “double complexity”, with the potential for a higher overall bill if things are not planned and reported carefully.

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Planning Ahead: How to Avoid the Grey Areas

You do not need to turn your life upside down just to keep the tax rules happy. The aim here is simply to make sure your position is clear, rather than drifting into a situation where New Zealand still thinks you are based there while the UK has quietly decided you have arrived for good.

A bit of planning before you leave, and some basic tracking in your first UK year, can go a long way.

Steps to consider before leaving New Zealand

If you do not really have a “home” in New Zealand

A lot of Kiwis heading to the UK do not actually own a house. You might be renting a room in a flat, living with parents or grandparents, or staying with friends. In those cases, there is often no New Zealand dwelling that clearly looks like your permanent place of abode once you leave. That does not mean residency ends the moment you get on the plane, but it does mean you are already part way there. The main thing for you is to make sure you genuinely give up that base when you move, and then keep an eye on the 325 day rule so you know when your New Zealand tax residency has actually come to an end.

If you do have a “home”, decide what you will do with it

One of the biggest drivers on the New Zealand side is whether you still have a permanent place of abode. That usually comes back to what is happening with your home.

Think carefully about whether you will:

  • Sell the property
    Often the cleanest outcome. If the house is sold and you have genuinely shifted your life offshore, it becomes much harder for Inland Revenue to argue that NZ remains your long term base.
  • Rent it out on a genuine long term basis
    A proper long term tenancy, where the property is no longer really available for you to live in, can also help show that your home base has moved. Short gaps between tenants are fine, but the overall pattern should be that someone else lives there, not you.
  • Leave it available “just in case”
    Keeping a house empty, or lightly using it between short-term lets, often looks like your NZ base is still very much intact. This is where permanent place of abode can linger, even if you are physically overseas for long periods.

There is no one right answer, but deciding this early and documenting what you actually do with the property makes later conversations much easier.

Take practical steps that reflect where your life is going

Rather than anything dramatic, focus on factual changes that show your centre of life is moving:

  • move everyday banking and key services to the UK once you arrive
  • update postal addresses over time so that important correspondence follows you
  • think about school, healthcare, clubs and professional memberships, and where those now sit

None of these things on their own will decide residency. Together, they help paint a consistent picture of where you really live.

Steps to consider when arriving in the UK

Track your UK days from day one

From the first day you land, keep a simple record of where you are. The Statutory Residence Test is very day based. Being able to show when you arrived, when you left, and how much time you spent here is fundamental.

Assume UK Tax Residency from Day 1

If you are leaving NZ for the UK to work, then in just about every scenario, you will become UK tax resident on the day you land. In our experience it’s very rare for this to not be the case. When thinking about tax, assume UK tax residency applies from Day 1.

Do not rely on assumptions or what a friend said

Everyone knows someone who “just did X and it was fine”. Their facts will not be the same as yours.

If you own property, have family in different countries, or are working remotely for a New Zealand employer while living in the UK, it is worth getting proper advice on your specific situation rather than leaning on pub chat or online forums.

A small amount of planning and clarity at the start is almost always cheaper and less stressful than trying to untangle two sets of residency rules after the event.

Wrapping It All Up

Dual tax residency is not something most Kiwis will ever face, but the rules can definitely catch you out if you are not clear on how New Zealand and the UK each look at your situation. The year you leave NZ and arrive in the UK is often the messiest on paper, which is why it pays to think about residency before you are knee deep in tax returns.

With a bit of planning around your New Zealand home, your travel pattern, and your first year in the UK, it is usually possible to keep things straightforward. You do not need to become an expert in the legislation, you just need to make sure your real life story and the tax rules line up.

At No Worries Accounting, we spend a lot of time talking to Kiwis who are either planning the move or already living in the UK and trying to make sense of the two systems. If you are thinking about leaving New Zealand, have recently arrived in the UK, or you are worried you might be in one of these grey areas, feel free to get in touch for a quick chat. A short conversation now can save a lot of head scratching later.

Note to Editors: This article was written by the humans at No Worries Accounting and contains original content. We are happy for you to repost part (or all) of it, but if you do please attribute the content to “No Worries Accounting” with a link to https://www.no-worries.co.uk/blog/. If you want further information or commentary from the experts at No Worries Accounting just ask 🙂 You can reach us here.

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