Each European country has its own tax rules, filing systems and treatment of foreign assets and these often differ significantly from the UK.
Most European countries have double tax agreements (DTAs) with the UK, designed to help prevent the same income being taxed twice. However, these treaties do not apply automatically and need to be interpreted correctly.
Understanding tax residency, your ongoing UK tax responsibilities and how your income, pensions and assets will be treated in your chosen European country is essential before you move.
Disclaimer
This article provides general guidance and should not be considered tax or financial advice. Rules vary by country and change regularly. If you need personalised support, we can introduce you to a relevant tax specialist. We also have more detailed guides on specific jurisdictions.
There is no unified European tax system
The EU does not administer income tax, capital gains tax or wealth taxes for member states. Each country sets its own rules. For example:
- Spain may apply regional wealth taxes and overseas asset reporting
- Portugal has different residency classifications and special tax regimes
- Italy may tax investment income differently from the UK
- France often applies social charges in addition to income tax
Assuming that taxation across Europe is broadly aligned with the UK can lead to costly mistakes.
Double tax treaties and how they work
The UK has double tax treaties with most European countries. These agreements help determine which country has the right to tax:
- Employment income
- Rental income from UK or overseas property
- Dividends and interest
- Pensions
- Capital gains
- Business and self-employment income
Treaties do not eliminate tax by default. You may need to apply for relief or provide proof of taxes paid elsewhere.
Tax residency: UK and Europe
UK tax residency status
The UK uses the Statutory Residence Test (SRT), which considers:
- Days physically present in the UK
- Family and accommodation ties
- Work and economic ties
- Previous residency patterns
Even after leaving the UK, it is possible to remain UK tax resident unintentionally if strong ties remain.
Split Year Treatment
In the tax year you leave the UK, you may not be treated as UK tax resident for the full tax year. Under Split Year Treatment, the year can be divided into:
- a UK part, where you are taxed as a UK resident on worldwide income, and
- an overseas part, where you are generally taxed as a non-resident and normally only on UK-sourced income.
Split Year Treatment is not automatic. It applies only if you meet specific conditions, which depend on whether you are:
- leaving the UK to work full-time overseas, or
- leaving to live abroad, or
- accompanying a partner who is working full-time overseas.
Correctly applying Split Year rules may reduce double taxation and help align your UK and European tax filings.
Tax residency in Europe
Most European countries consider:
- Days spent in-country (often 183+ days)
- Your main home
- Centre of vital interests (family, income, relationships, business)
- Habitual residence
Once tax resident, you may become liable on your worldwide income, not only local income.
UK tax obligations after leaving the UK
You may still have UK tax responsibilities if you keep UK-based income or assets.
You may need to file Self Assessment if you continue to receive:
- UK rental income
- Certain UK pension income
- UK employment or business income
- Capital gains on UK property or some other UK assets
UK Capital Gains Tax (CGT) on UK assets after moving to Europe
Leaving the UK does not automatically remove you from UK Capital Gains Tax. If you sell UK residential property while living abroad, you will normally still be subject to UK CGT and must submit a 60-day CGT return and pay any tax due within that deadline. A key exception is where the property qualifies in full as your main residence, which may reduce or eliminate CGT, subject to conditions and periods of occupation.
For non-property assets, the rules are more nuanced. In many cases, once you are non-UK tax resident, gains on non-UK assets fall outside UK CGT. However, if you return to the UK within a certain timeframe, the temporary non-resident rules may apply. This can mean UK CGT becomes due on gains realised while abroad if you were non-resident for fewer than five complete tax years.
Because timing can materially affect the tax due in both the UK and your new country, people intending to sell UK property, shares or other assets often benefit from advice before they become tax resident abroad.
For a full explanation and understanding, see our article: Capital Gains Tax for Expats and Non-Residents
Inheritance tax in the UK and Europe
From April 2025, the UK is moving to a residence-based Inheritance Tax system, which means your exposure to UK IHT may continue even after leaving if you have been UK tax resident for 10 out of the previous 20 tax years.
UK assets, such as property, normally remain within the IHT net regardless of where you live, but non-UK assets may also be in scope depending on your UK residency history. If you are planning a long-term move, it can be important to understand when your UK IHT exposure may taper or end.
It is also essential to consider inheritance and succession rules in your destination country. Europe does not have a single inheritance tax regime and several countries apply forced-heirship rules, meaning part of your estate may have to pass to certain family members, regardless of your will.
Some countries tax the heir, rather than the estate, and many do not have Inheritance Tax treaties with the UK, which may create a risk of double taxation if no planning is done.
People relocating to Europe with property, pensions, savings or family wealth in more than one country often benefit from speaking to a UK and local adviser to coordinate cross-border estate planning and ensure their wills reflect their new circumstances.
Notifying HMRC aboutyour departure
Departure should be reported via a P85 or Self Assessment so HMRC has a clear record of your change of status.
Filing UK tax returns as a non-resident
If you continue to have UK tax reporting duties after you move, you will usually need to complete a Self Assessment tax return.
However, the standard online filing system does not always support the forms required to correctly report non-resident status and claim double tax relief. In many cases, non-residents must either file using commercial tax software or submit a paper return including the relevant supplementary pages (such as SA109).
Because HMRC needs sufficient evidence to accept your non-resident position, many people seek professional help the first time they file as a non-resident to ensure the return is completed correctly and their residency status is clearly established.
How your assets may be taxed differently in Europe
Many UK tax-efficient assets lose their benefits once you become tax resident elsewhere.
Examples include:
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Asset / Income
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Typical changes
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ISAs
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Often no longer tax-exempt and may be taxed annually
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Investment funds/ETFs
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May be taxed less favourably than in the UK
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Pensions
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May be taxed by the UK, European country, or both depending on treaty terms
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Dividends and rental income
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May attract different tax rates and/or social charges
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Crypto and digital assets
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Reporting and taxation vary significantly
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Company directors and dividend income
If you are a director or shareholder of a UK limited company and plan to keep receiving salary or dividend income after moving to Europe, it is important to understand how this may be taxed.
Many European countries will treat dividends from a UK company as taxable foreign investment income, and rates can differ significantly from the UK. Some countries also apply social taxes or surtaxes in addition to income tax.
Under most double tax treaties, the UK may still withhold tax on dividends, but your new country of residence may have the primary taxing right. You will normally need to declare the income locally and then claim any treaty relief to avoid double taxation.
People running a business from Europe should also confirm whether their move creates a tax presence or “permanent establishment” in the new country, which may trigger local corporation tax or reporting requirements.
If you own a company or receive dividends, it is usually best to get both UK and local tax advice before changing residency, as restructuring options may be more effective before the move.
Currency effects and paying tax in different currencies
When you move to Europe, you may find that your tax liabilities must be calculated and paid in different currencies.
UK taxes are paid to HMRC in pounds sterling (GBP), while most European countries require tax payments in euros (EUR). If your income, pensions or asset sales are in one currency but your tax is due in another, currency fluctuations can create unexpected gains or shortfalls, even when your underlying income has not changed.
For example, if you owe UK CGT on a property sale but hold most of your wealth in euros, a shift in the exchange rate could mean you need to convert more euros than expected to cover the GBP tax bill.
Similarly, if you owe tax in Europe but hold funds in pounds, you might overpay or underpay if the exchange rate moves between calculation and payment.
Careful planning, and in some cases using a specialist currency provider, can help reduce the risk of currency-related tax problems and support better timing of transfers.
If a significant transaction or tax payment is expected, many people find it useful to discuss currency strategy alongside tax planning, especially when relocating with property, pensions or investment income.
Reporting and compliance in Europe
Some countries require reporting of overseas assets, including bank accounts and investments, for example:
- Spain’s Modelo 720
- Foreign account disclosures in France
- Reporting obligations in Portugal and Italy
In some European countries, wealth taxes may also apply.
Tax relocation timeline
The following timeline should help you understand when reading and researching is enough and when you should start speaking to specialists and taking action to stay compliant with all applicable tax rules.
6 months or more before moving: Research
- Get an understanding of the basics of UK tax residency, double tax treaties, and local tax residency rules.
- Understand how your income, pensions, property and ISAs might be taxed differently.
- Identify whether Split Year Treatment might apply for the year of departure.
Within 6 months of your move: Planning and structuring
- Get country-specific guidance once you know where you are moving.
- Review potential property, investment or pension decisions before becoming tax resident abroad.
- Select a strategy for managing currency and future tax payments (GBP vs EUR).
- Get advice about timing your move if you have flexibility.
0 to 60 days before moving: Implementation and action
- Notify HMRC (P85 or via Self Assessment).
- Secure documentation for proving UK non-residency if needed later.
- Ensure access to required financial records for both tax systems.
First 90 days after arrival: Register and comply locally
- Register for tax and obtain any required tax ID / social security number.
- Confirm whether you must report overseas assets or foreign bank accounts.
- Determine whether you will need local advance or quarterly payments.
End of first tax year: File returns and reconcile
- Complete any required UK Self Assessment (if applicable).
- File your first local tax return and claim double tax relief if required.
- Review asset and currency positions for the next tax cycle.
Related reading: UK tax guides for expats
Get help directly from UK and local tax specialists
Technically you can manage your taxes yourself, however, even UK tax matters get much more complex and stressful once you move abroad. Local taxes can be nuanced and forms are rarely translated into English, so local assistance is a must to ensure that you don’t make any mistakes.
If you already know that you are moving to Europe, or are close to making that decision, we can introduce you to a UK and local tax specialist who can:
- Confirm your expected tax residency position
- Help ensure your UK and European reporting is correct
- Review your pensions, investments and property position
- Highlight tax implications of timing asset sales or transfers
- Identify any risks before they become expensive issues
This service is not designed to fill general knowledge gaps. It is most useful when:
- You have chosen or are close to choosing a country, and
- You want to ensure your tax position is correctly structured before or shortly after relocating
Requesting an introduction is free and you may also be eligible for a free discovery call with one of our trusted partners. There is no obligation to proceed with paid advice.