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How does HMRC determine tax residency for individuals with multiple homes in 2025?
Executive summary
HMRC determines individual tax residence primarily using the Statutory Residence Test (SRT): automatic tests (like 183 days in the UK or having a UK home for 91 consecutive days) then, if neither automatic test applies, the “sufficient ties” test which counts family, accommodation, work, 90‑day and country ties [1] [2]. Since 6 April 2025 the UK shifted from domicile-based non‑dom rules to a residence‑centred system and introduced transitional regimes (notably a four‑year Foreign Income and Gains relief for qualifying new residents); this increases the stakes of being found resident [3] [4] [5].
1. How the SRT orders the decision: automatic tests first
HMRC applies the Statutory Residence Test in tiers: you are first checked against automatic overseas tests and automatic UK tests (for example, spending 183+ days in the UK or having “a home in the UK for 91 consecutive days” where you are present for 30+ days makes you automatically resident) [2] [6]. If you meet an automatic test, no further balancing of ties is needed; if you do not meet any automatic test, HMRC applies the sufficient‑ties test to decide residency [1] [2].
2. When multiple homes matter: the accommodation tie and the 91‑day rule
Having more than one property is central to the accommodation tie. If you own, rent, or regularly use a UK property that is available to be used as a residence for 91 consecutive days (and you spend at least one night there in the tax year), that creates an accommodation tie; if you have multiple UK homes the test can be met by any one of them when considered separately from the others [1] [7]. The automatic UK home test also turns on 91 consecutive days (with at least 30 days falling in the tax year) and whether you have no overseas home or you spend under 30 days at each overseas home in that period [6] [7].
3. Counting days: physical presence remains decisive
Physical presence rules remain fundamental: days present in the UK are counted (a day is generally counted if you are in the UK at the end of that day), and thresholds (for example 183 days) remain determinative for automatic residency [1] [2]. The sufficient‑ties test combines the number of UK days with how many UK “ties” you have to reach residency; fewer days require more ties, more days require fewer ties [1] [8].
4. The “ties” that turn a traveller into a resident
The SRT lists five main ties: family (spouse/partner or minor children resident in the UK), accommodation (as above), work (40+ UK work days), the 90‑day tie (90+ days in either of the previous two tax years), and the country tie (the UK is the country where you spend the most time compared with any other country). HMRC and advisers explicitly use these ties to calculate residency under the sufficient‑ties test [1] [9].
5. Practical proof: records, banks and global reporting
HMRC increasingly receives international financial data (CRS and other digital feeds), so passive foreign income and overseas accounts are more visible than before; advisers warn that relying on informal assumptions about non‑residence is riskier in 2025 [9]. To justify a residence claim you should keep documentary evidence of days, accommodation availability, work patterns, and family circumstances — HMRC may ask for such proof [3] [9].
6. The 2025 policy shift and why it changes behaviour
From 6 April 2025 the government moved from the historic non‑dom/remittance basis towards a residence‑based system and introduced transitional measures such as a four‑year Foreign Income and Gains (FIG) relief for qualifying new residents; that means residence status now largely determines tax on worldwide income and has implications for trusts and inheritance tax exposure [3] [4] [10]. Multiple sources note this is a fundamental policy shift that raises consequences for people with second homes or split living patterns [5] [10].
7. Common pitfalls and contested interpretations
HMRC guidance and professional advisers caution that simple heuristics (e.g., “under 183 days = non‑resident”) are unsafe: split years, temporary non‑residence rules, and the interplay of multiple homes complicate outcomes [8] [11]. Some firms emphasise that HMRC now expects a reduction in UK connections to be meaningful if you claim non‑residence, citing recent case law and guidance where frequent UK presence still produced residency findings [12] [13].
8. What to do next: recordkeeping and professional advice
Because the SRT mixes objective day counts with fact‑sensitive ties and the 2025 reforms change global tax exposure, advisers recommend comprehensive records of arrivals/departures, nights spent at each home, lease/ownership documents, work patterns and family arrangements, and early professional advice for anyone with multiple homes or cross‑border income [9] [1]. Available sources do not mention specific HMRC online tools beyond existing guidance; check HMRC and specialist advisers for personalised planning [3] [1].
Limitations: this analysis relies on practitioner guides and summaries in the supplied reporting and HMRC‑focused commentary; for an individual determination you must consult the detailed SRT legislation, HMRC’s official guidance, or qualified tax advisers [1] [2].