Keep the house in the UK and try Ireland first?
That can work. Two homes are not a tax no man’s land but a situation with clear rules, two tax returns and a few points you should keep in order from the start.
A normal decision
Anyone moving to another country with children is slow to burn their boats. Keeping the house at home so that you can go back at any time is therefore not the exception but the rule of the first years, and there is no reason to treat it like a confession.
For tax, the decision has a price, and it is easier to name than the subject sounds: the house you keep is a tie to the UK, and whether that tie keeps you UK resident is decided by your days in the country. Anyone who knows that and plans for it gets an arrangement that runs quietly. Anyone who ignores it gets letters from HMRC.
This page describes the arrangement, then the UK side in detail, and at the end, in all clarity, who it is not for.
The arrangement: two returns, two pots
This is what the orderly version looks like, and it is less spectacular than the advertising for offshore models would suggest.
In Ireland you are resident and, as a non-dom, use the remittance basis. Your Irish return contains your Irish income and whatever you actually bring into Ireland. Your other income stays outside and does not appear there. For British readers one detail matters: according to Revenue’s manual on the subject, the remittance basis has covered UK-source income since 2008 as well.
At home, tax carries on: the UK goes on taxing your UK income, the rent on a house you let, interest and other UK sources, whether or not you are still UK resident. You accept that, because that is exactly the price of the open back door.
The result is two returns with nothing hidden: Ireland gets the Irish pot, the UK keeps its own, and by design nothing is taxed twice, because each pot appears only once. The Irish side of this, registering with Revenue and the first return, is what our tax registration as a non-dom takes on.
That this division works out cleanly is down to a clause in the UK-Ireland convention that has its own page on this site: the remittance clause. It makes sure that UK income which does not flow to Ireland stays within UK tax. For the arrangement on this page it is not a restriction but the mechanism that carries it: it is the reason the two pots do not collide.
| What | Where in the UK-Ireland convention |
|---|---|
| Income | Article 6, Limitation of relief |
| Capital gains | Article 14(5), proviso |
Source: HMRC, “Synthesised text of the Multilateral Instrument and the 1976 UK-Ireland Double Taxation Convention” and “1976 UK-Ireland Double Taxation Convention as amended by the 1998 Protocol”, both on GOV.UK (updated 13 August 2019). As of: read 6 November 2026.
Two building blocks belong in place from the start: the account structure on the page The account before 1 January, so that the pots are separate in the bank as well, and the cards in your wallet, because every Irish payment from a foreign account is a remittance.
Where you are resident, and what that changes
With two homes you can be resident under the law of both countries: in Ireland through your days there, in the UK through the statutory residence test. For the convention that cannot stay so; the Irish tax administration puts it plainly in its own manual: for the purposes of a treaty a person cannot be resident in both states.
The convention of 1976 decides the question in Article 4(2), in a fixed order: permanent home, centre of vital interests, habitual abode, nationality, and finally agreement between the two tax authorities. With a home in each country the first step does not decide, and the second does. Where the family lives, where the children go to school, where everyday life happens: for a family that really lives in Ireland, treaty residence therefore as a rule sits in Ireland, and the house you keep does not change that.
What matters is what this result changes and what it does not. It changes the division: the UK may then tax only what the convention leaves to the country of source, above all UK property and UK income, while your salary for work done in Ireland stays with Ireland under Article 15. It does not change UK residence itself: if the residence test makes you UK resident, you stay so under UK law, with a return to file and with effect on everything the convention leaves to the UK. Anyone who thinks the tie-breaker signs them off in the UK is mixing up two levels.
| Level | What decides | Consequence |
|---|---|---|
| UK law | the statutory residence test: days in the UK and ties to it (Finance Act 2013, Schedule 45) | UK resident: worldwide income and gains as they arise; non-resident: UK income and UK land only |
| The convention | Article 4(2): permanent home, centre of vital interests, habitual abode, nationality, agreement | the UK keeps only what the convention leaves to the country of source |
The convention cannot decide residence for UK law; it only limits what the UK may make of it.
Source: UK-Ireland convention, Article 4(2), HMRC synthesised text on GOV.UK; Revenue, Tax and Duty Manual Part 34-00-01, section 6.3.3. As of: convention read 6 November 2026, Revenue as verified on the German page.
The UK: a home is a tie, not a verdict
The UK side differs from most of Europe in one point, and it is the point that reassures. Under the statutory residence test a house you keep does not by itself make you UK resident. What decides is a sequence of tests, set out in HMRC’s guidance RDR3.
First the automatic overseas tests. If you were UK resident in at least one of the three previous tax years, you are non-resident for a tax year in which you spend fewer than 16 days in the UK. Then the automatic UK tests: 183 days or more make you resident, and so does the home test. That test asks for a UK home for at least 91 consecutive days, in which you are present on at least 30 days in the year, while you have no overseas home or spend fewer than 30 days in it. A family that lives in its Irish house spends far more than 30 days there, so the home test does not catch you.
What remains is the sufficient ties test, and there the house counts. You have an accommodation tie when a place to live in the UK is available to you for at least 91 consecutive days in the year and you spend at least one night there. Further ties are family, work, more than 90 days in the UK in either of the two previous tax years and, for someone leaving, the country tie. The more ties you have, the fewer days you may spend in the UK before you are resident again:
| Days in the UK in the tax year | UK ties that make you resident |
|---|---|
| 16 to 45 | at least 4 |
| 46 to 90 | at least 3 |
| 91 to 120 | at least 2 |
| over 120 | at least 1 |
From the fourth tax year of non-residence the stricter Table B of RDR3 applies, which starts at 46 days and needs more ties.
Source: HMRC, “RDR3: Statutory Residence Test (SRT) notes” (updated 11 June 2026); Finance Act 2013, Schedule 45, paragraphs 34, 37 and 46, legislation.gov.uk. As of: read 6 November 2026.
For the arrangement on this page that means: anyone who keeps the house, stays in it for a few weeks a year and keeps an eye on the days can be non-resident in the UK while the family lives in Ireland. Anyone who spends half the year in it stays resident, and then the convention decides, as described above.
The UK: what follows, and the way back
If you are non-resident, GOV.UK states the rule in one sentence: you do not pay UK tax on income or gains you get outside the UK. What stays in the UK is UK income, such as the rent on the house if you let it, and gains on UK property or land. The current treatment of letting is on the page Rental income.
If you are still UK resident, the UK has taxed every resident on worldwide income and gains as they arise since 6 April 2025, when the remittance basis was abolished. If treaty residence then sits in Ireland, the convention cuts that back to what it leaves to the UK. The exact technique of the return in a dual residence year belongs in the consultation, not on a website; the basic order is the one described here. One consequence of the house belongs here, though: it closes the split-year route for people who give up their UK home, because Case 3 of the split-year rules requires that you have no home in the UK for the rest of the tax year.
And the point that reassures these readers most: the back door is open, and the UK charges individuals no exit tax for walking through it. The door has a hinge, though, and you should know it. Anyone who was solely UK resident in at least 4 of the 7 tax years before leaving and comes back within 5 years is temporarily non-resident. Gains on assets held before leaving and realised in between are then taxed in the year of return, and so are certain kinds of income, such as distributions from a family company; the convention does not prevent that (section 1M(4) of the Taxation of Chargeable Gains Act 1992). A year in which the convention made you Irish resident counts as a year away. If you sell nothing and take nothing of that kind out in the meantime, coming back costs nothing extra. What the UK still claims on a final departure is on the page Leaving the UK: what is taxed.
Who this is not for
This section is short, and it applies without exception.
Anyone who wants the move to Ireland to mean paying no tax at all on their income, not even in the UK, must not under any circumstances keep a foothold in the UK that makes them resident there. A house you live in for half the year lays the UK’s net over exactly the income that is meant to stay free under that aim, and so destroys the structure completely. There is no arrangement that delivers both: the open back door with months at home, and freedom from tax on your income from home.
How the full move works for tax is set out on the pages Non-dom and The remittance clause; what has to be wound up in the UK along the way does not belong on this page but in the consultation.
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