Cross-Border Tax Accountants
Cross-Border Tax Accountants: directory of firms
UK tax follows residence, not citizenship. A British passport does not make someone UK taxable, and losing one does not end a UK liability. Residence is decided by the statutory residence test, which counts days and weighs ties against a defined set of rules, and the answer can change from one tax year to the next without anything else about a person's life changing much.
Browse cross-border tax accountants by city, and see what to check before you hire.
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On this page
Cross-border work comes up when someone moves to or from the UK, works abroad for a UK employer, holds foreign assets or income, or is taxed by two countries on the same money. It also comes up for non-residents who keep UK property or UK employment income, since gov.uk states that you usually have to pay tax on UK income even when you are not UK resident.
The rules changed materially on 6 April 2025, when the four-year foreign income and gains regime replaced the remittance basis for new arrivals. National Insurance runs on a separate track from income tax, with its own agreements and certificates. Any adviser who treats the two as one thing, or who answers a residence question without asking about day counts and ties, is not doing cross-border work.
UK residence is a test, not a decision you make
Gov.uk sets out automatic UK tests: spending 183 or more days in the UK in the tax year; having your only home in the UK for 91 days or more in a row and staying in it for at least 30 days of the tax year; or working full-time in the UK for any period of 365 days with at least one day of that period falling in the year being checked.
There are automatic overseas tests that point the other way. Spending fewer than 16 days in the UK, or fewer than 46 if you have not been UK resident in the three previous tax years, makes you non-resident. So does working abroad full-time, averaging at least 35 hours a week, while spending fewer than 91 days in the UK of which no more than 30 were spent working.
If neither set of automatic tests settles it, the sufficient ties test combines day count with connections such as work and family. The arithmetic is unforgiving, and keeping a contemporaneous record of travel dates is the single most useful habit for anyone near a threshold.
The four-year foreign income and gains regime replaced the remittance basis
On 6 April 2025 the four-year foreign income and gains regime replaced the remittance basis. It is available to a qualifying new resident: someone who is UK tax resident under the statutory residence test and still within their first four years of UK residence following at least ten consecutive tax years of non-UK residence.
A claim must be made for each year the relief is wanted, and it runs for a maximum of four consecutive tax years from the year residence began. Unused years cannot be carried forward, and a year of temporary departure means the regime is unavailable for that year.
There is a trade. Claiming means giving up tax-free allowances for Income Tax and Capital Gains Tax, along with Married Couple's Allowance, Marriage Allowance and Blind Person's Allowance. Whether the claim is worth making is an arithmetic question that has to be answered year by year.
Situations that need cross-border tax advice
- Arriving in the UK to work, particularly part way through a tax year.
- Leaving the UK while keeping a home, a company or a rental property behind.
- Working abroad for a UK employer, or in the UK for a foreign employer.
- Holding foreign bank accounts, investments, pensions or property while UK resident.
- Inheriting assets located outside the UK.
- Selling UK land or property as a non-resident, which is reportable even when other gains are not.
Double taxation and how relief is actually claimed
Two countries can each have a legitimate claim on the same income. The UK's network of double taxation agreements allocates taxing rights between them, and gov.uk notes that where your country of residence taxes your UK income, relief may be available so that you are not taxed twice on the same amount.
Relief is not automatic. It usually has to be claimed, sometimes in both countries, sometimes with a certificate of residence, and frequently within a time limit. Non-residents may still be entitled to a UK Personal Allowance, and where too much tax has been deducted a repayment can be claimed using form R43 or through a Self Assessment return.
Non-residents remain liable on UK pensions, rental income, savings interest and wages, while State Pension and interest on UK government gilts are normally outside the charge.
National Insurance follows its own rules
Income tax residence and social security liability are decided separately, and a person can easily be resident for tax in one country and paying social security in another. Where the UK has an agreement with the country concerned, a certificate of coverage shows that National Insurance is being paid in the UK, so contributions are not owed twice.
Without an agreement, gov.uk sets out a 52-week rule: UK National Insurance is due for the first 52 weeks abroad if you are working abroad temporarily, your employer has a place of business in the UK, you are ordinarily resident in the UK, and you were living in the UK immediately before starting the work.
Voluntary contributions can be paid while abroad to protect State Pension entitlement. That is a long-term decision worth taking deliberately rather than discovering decades later.
How a cross-border engagement usually runs
- A fact-find covering travel dates, homes, family, work pattern and prior residence history.
- A residence determination for each tax year in question, documented with the test relied on.
- A review of income and gains by source and location, and which country has the taxing right.
- A decision on any claim to be made, including whether the four-year regime is worth the lost allowances.
- Coordination with an adviser in the other country, because neither side can file correctly in isolation.
- Filing and record retention, keeping the day-count evidence in case the position is questioned.
Why you usually need an adviser on both sides
- A UK adviser can determine UK residence and UK liability, but cannot certify the other country's treatment.
- Treaty relief often depends on paperwork issued by the other jurisdiction to a deadline.
- Filing dates rarely align, and one country's year end can fall mid-way through another's.
- Pension and share scheme treatment frequently differs, so the same plan can be taxed twice in different ways.
- Agree in writing which adviser owns which filing, or something falls between them.
Cross-Border Tax Accountants: frequently asked questions
Does being a British citizen make me UK taxable?
No. UK tax follows residence, decided by the statutory residence test. Citizenship is not one of its tests. A non-resident can still owe UK tax on UK-source income such as rent, wages, savings interest and pensions.
How many days can I spend in the UK without becoming resident?
There is no single number. Spending 183 or more days in a tax year makes you automatically resident. Spending fewer than 16 days, or fewer than 46 if you have not been UK resident in the three previous tax years, makes you automatically non-resident. In between, the sufficient ties test combines day count with connections such as work and family, so the safe number depends on your ties.
Can I still use the remittance basis?
Not for years from 6 April 2025. The four-year foreign income and gains regime replaced it. A qualifying new resident is someone still within their first four years of UK residence after at least ten consecutive tax years of non-UK residence, and claiming means giving up Income Tax and Capital Gains Tax allowances for that year.
I am moving abroad but keeping my UK rental flat. What changes?
The rental income stays within the UK charge, because gov.uk states that you usually pay tax on UK income even when you are not UK resident, and you will normally need to file a Self Assessment return for it. Whether your new country also taxes it depends on the relevant double taxation agreement, and relief generally has to be claimed rather than applied automatically.
Will I pay National Insurance in two countries?
Usually not, if a social security agreement covers the country concerned: a certificate of coverage shows contributions are being paid in the UK. Without an agreement, UK National Insurance can still be due for the first 52 weeks abroad where the employer has a UK place of business and you were living in the UK immediately before the posting.
Sources
Written by the LokalMatch editorial team. Last reviewed 22 September 2026. How we write and check our guides
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Northern Ireland
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What affects the fees cross-border tax accountants charge
Fees depend on the work involved and how the professional bills. We only publish fee ranges when they’re backed by real LokalMatch data or reliable sources. Until then, here’s what usually changes the fee:
- Scope and complexity of the work
- How the professional bills: hourly, flat fee or retainer
- Experience and seniority of the person doing the work
- Deadlines and how urgent the work is
- Third-party costs such as filing, registration or government fees
How to compare cross-border tax accountants before you hire
- Check that they are licensed or registered for this work where you live, on the regulator’s public register.
- Look for experience with matters like yours, and ask who will actually handle your file.
- Ask how they charge before any work starts, and get the terms in writing.
- Compare two or three professionals before you decide.
- Be wary of anyone who guarantees a particular outcome.
Questions to ask cross-border tax accountants before you hire
- Are you licensed or registered for this work, and with which body?
- Have you handled matters like mine before?
- Who will do the work, and who will I deal with day to day?
- How do you charge: hourly, a flat fee or a retainer?
- What is included in your fee, and what costs extra?
- Will you confirm the scope and fees in a written engagement letter?
- Do you carry professional liability insurance?
Licences and registration
This kind of work is often limited to licensed or registered professionals, and the rules depend on where you are. Ask which body they’re registered with, and check their status on that body’s public register before you hire.
Guides about cross-border tax
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Accountants guide
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Bookkeepers guide
Bookkeeping is the daily record of what a business earned, spent, owes and is owed. In the UK it has stopped being a shoebox job.
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Tax Accountants guide
A tax accountant is hired for judgement rather than data entry. The questions are usually about how a transaction should be structured, whether a relief applies, how to unwind something that was done badly, or how to…
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