Dual Tax Residency

Dual Tax Residency in the UK: Are You Being Taxed Twice?

With more professionals working across borders — between the UK, Ireland, and France in particular — dual tax residency has moved from a niche concern to an everyday reality for thousands of people. The good news is that being taxed in two countries is not inevitable. The bad news is that if you don't plan proactively, it very often happens anyway.

How does dual tax residency arise?

You become a dual resident when two countries simultaneously consider you tax-resident under their own domestic rules. For the UK, residency is determined by the Statutory Residence Test (SRT), which looks at the number of days spent in the UK, the number of "ties" you have here (family, home, work, 90-day test), and whether automatic overseas tests apply. Ireland and France each have their own equivalent tests — and all three can point to "resident" at the same time.​

Common triggers for UK-based clients:

• Spending 183+ days in a second country during the tax year

• Maintaining a permanent home in both the UK and France or Ireland simultaneously

• Being a UK company director who has relocated overseas but retains UK economic ties​

Do Double Tax Treaties protect you?

The UK has Double Tax Treaties (DTTs) with over 130 countries, including both Ireland and France. These treaties allocate taxing rights between the two countries on a source-by-source basis — employment income, rental income, dividends, and pensions are each handled differently. France and Ireland also have their own bilateral treaty covering cases where income originates from a third country, including the UK.

Critically: a DTT does not eliminate your filing obligation. Even if no additional tax is due after treaty relief, you may still be required to file returns in both countries. Non-filing penalties in France and Ireland are substantial.​

What the abolition of the UK non-dom regime means for you

Since April 2025, the non-dom regime has been replaced by a new four-year Foreign Income and Gains (FIG) exemption for new arrivals. For long-term residents who previously relied on remittance basis, this represents a fundamental shift in planning strategy — and dual residency structures that previously worked cleanly may need to be revisited.​

Three situations that require immediate advice:

1. You spent significant time in France or Ireland in the 2025/26 tax year and had full UK PAYE deducted

2. You receive rental income, dividends, or a pension from a country different to where you now live

3. You are a director of a UK-registered company but are now primarily resident overseas

Living between the UK, Ireland, or France? You may have tax obligations in both countries. Here's what dual residency means — and how to manage it.

Our advice: Dual residency is not inherently a problem — in some cases it can be structured advantageously. But it requires proactive planning, not reactive filing. Book a call with our team to review your position before the 5 April 2026 year-end.