UK split year treatment for Swiss salary (2025/26)
UK split year treatment for Swiss salary: is it taxable in the UK? Case 1 can exclude overseas earnings. See the day limits for 2025/26 and 2026/27.
If I start working in Switzerland in the 2025/26 UK tax year and later return to the UK, when is my Swiss salary outside UK tax?
Case 1 split year treatment can keep earnings from duties performed in Switzerland outside UK tax during the overseas part of 2025/26. It requires meeting the full-time overseas work test in 2026/27. The outcome depends on your work pattern, UK visits and treaty residence.
The example covers a departure in 2025/26, a full overseas year in 2026/27 and a possible return in 2027/28. The day limits below are statutory limits for the periods described.
The departure year under Case 1
Consider a UK resident who takes a full-time job in Switzerland and makes occasional visits back to the UK. Case 1 requires UK residence in the departure year and the preceding year. The employee must also meet the overseas work criteria for a qualifying period ending on 5 April 2026 and pass the third automatic overseas test in the following tax year.
The qualifying period must start on a day when the employee works more than 3 hours overseas. If it starts in June, the limits for that period are 75 UK days and 25 UK workdays. Different start months have different limits. Keep a record of travel dates and hours worked in each country so you can check both counts.
The full overseas year
The UK tax year runs from 6 April to 5 April. To meet the third automatic overseas test for 2026/27, you must satisfy all of these conditions:
Work sufficient hours overseas. HMRC applies a calculation based on 35 hours a week, with adjustments for specified days and periods.
Spend at most 90 days in the UK.
Work more than 3 hours in the UK on at most 30 days.
Have no significant break from overseas work. Broadly, this means a period of 31 days or more without a day of more than 3 hours of overseas work or a qualifying day of leave when you would otherwise have worked those hours.
UK presence is generally counted at midnight. UK workdays are counted separately, so remote work from the UK can count even on a day when you leave before midnight.
If this test fails, Case 1 is unavailable for the departure year. Check the rest of the Statutory Residence Test for the full overseas year and whether another split year case applies in the departure year.
Which earnings can the UK tax?
When Case 1 applies, salary attributable to duties performed in Switzerland during the overseas part is generally outside UK tax. Pay attributable to duties performed in the UK during that period can still be taxable, subject to treaty relief. The 3-hour threshold is used for counting workdays under the residence test. Tax on employment income is a separate question.
If both countries treat you as resident under domestic law, the UK–Switzerland convention has separate residence rules. It looks first at where you have a permanent home and, if you have one in both countries, where your personal and economic relations are closer. Habitual abode and nationality are later steps in the treaty test.
Returning in 2027/28
A return from 6 April 2027 falls into a new UK tax year. If you become UK resident and cease full-time work overseas during that year, check whether Case 6 split year treatment applies. It has separate conditions, including the overseas work test for the preceding year and overseas work criteria for the relevant part of the return year.
The temporary non-residence rules can bring certain gains, pension withdrawals and company distributions into UK tax on return. Ordinary salary from employment abroad generally falls outside that regime. Whether the salary was taxable when earned still depends on the residence and employment income rules.
FAQ
Is there a five-year minimum stay in Switzerland for salary?
There is no general five-year minimum for ordinary salary. For a Case 1 departure, the decisive requirement is passing the third automatic overseas test in the tax year after departure.
Does the date on my Swiss contract start the overseas period?
Check the first qualifying day of actual overseas work. The qualifying period must begin on a day when you work more than 3 hours overseas.
Do visits after 5 April count towards the previous year's limit?
Days from 6 April fall in the new tax year. For travel around that date, record where you were at midnight and where you worked.
Where do I report split year treatment?
If you file a UK Self Assessment return, use the residence pages, SA109, to report split year treatment. Keep your travel and work records to support the position for both the departure year and the following year.
Sources
HMRC manual EIM40101, taxable earnings and split year treatment
UK-Switzerland Double Taxation Convention, consolidated text
This article explains the general framework and does not constitute personalised tax advice. Rules can change each year, and the tax treatment depends on your exact circumstances.
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