Guide · Any country · Tax

Moving to another country as a freelancer? Tax residence and the year you move (US, UK, Canada)

Where you're tax resident decides which country taxes your freelance income, and the year you move is the tricky one. Here's how the IRS, HMRC and the CRA each decide whether you're resident, what they say about the year you arrive or leave, and what to keep so you can show your dates.

General information, not tax or legal advice. Not written or reviewed by a lawyer or an accountant. The short answer, the side-by-side summary, the steps, the checklist, the wording to copy and all the other wording are ours; the official items come from the US, UK and Canadian government pages linked below. This page is about one move from one country to another by a self-employed person working on their own. It doesn't cover living in several countries in turn, students, diplomats, employees sent abroad by an employer, companies, US state or Canadian provincial residence, Quebec, immigration or visas, or the tax rules of countries other than the US, the UK and Canada. It doesn't tell you where you are resident: each test depends on your own facts. Official pages were read on .

The short answer

  1. Each country has its own test, and you can pass two at once. The US counts days (and green cards), the UK uses the statutory residence test, and Canada looks at the ties you keep.
  2. The year you move is usually split in some way: a dual-status year in the US, split-year treatment in the UK if you meet one of its cases, and a part-year return in Canada.
  3. US citizens are different: moving abroad doesn't end US tax on your worldwide income or your US filing.
  4. Leaving can have its own tax: Canada treats certain property as sold on the day you leave, and the UK can tax some income and gains if you come back after only a short time away.
  5. If two countries both treat you as resident, the tax treaty between them has tie-breaker rules.
  6. Keep proof of your dates: travel records, a day count, and the ties you kept or gave up.

On this page

1. United States: the IRS tests

If you're not a US person and have US clients, our guide for non-US freelancers with US clients covers the form they ask for and why the IRS looks at where you do the work.

2. The year you arrive in or leave the US

For how US freelancers report business income, see Schedule C for US freelancers.

3. United Kingdom: the statutory residence test

4. The year you arrive in or leave the UK

5. Canada: residential ties

6. The year you leave or arrive in Canada

Self-employment income goes on your usual statement of business or professional activities: see our guide for Canadian freelancers.

7. Resident in two countries

8. Side by side

Our summary of sections one to seven, not official wording.

QuestionUnited StatesUnited KingdomCanada
Who this row is aboutSomeone who is not a US citizen moving to or from the USAnyone moving to or from the UKAnyone moving to or from Canada
The main testThe green card test or the substantial presence test, which counts days in the current year and the two years beforeThe statutory residence test: the automatic overseas tests, the automatic UK tests, then the sufficient ties testResidential ties and all the facts; a long enough stay without ties can make you a deemed resident
Tax year it looks atThe calendar yearThe UK tax year, which runs from April to AprilThe calendar year
The year you moveOften a dual-status year: income from all sources while resident, US-source income only while notResident for the whole year, unless split-year treatment splits it into a UK part and an overseas partPart-year resident: world income while resident, certain Canadian income for the rest of the year
LeavingResidency usually ends on the last day of the calendar year; earlier with a foreign tax home, a closer connection and a statement. US citizens stay taxable on worldwide incomeTell HMRC; if you file Self Assessment, use the residence pagesUsually non-resident from the latest of the day you leave, the day your family leaves and the day you become resident elsewhere; certain property is treated as sold
ArrivingResidency usually starts on the first day you are in the US in the year you pass the substantial presence testSplit-year cases for arrivals; the foreign income and gains regime for some new residentsUsually resident from the day you arrive and set up ties; certain property you own is treated as bought at its value that day
Asking the tax authorityThe closer connection statement form, and a statement for an early residency ending dateHMRC’s residence status checker gives an indication onlyResidency determination forms for leaving or entering; the opinion isn’t binding on the CRA
Records to keepTravel dates and a day count for each calendar yearDays in the UK, days worked, homes and ties for each UK tax yearMove dates, ties kept or given up, and property values on the move date

9. Step by step

Our order of steps, based on sections one to seven — not an official checklist.

  1. Write down the day you plan to leave and the day you plan to arrive, and keep proof of both.
  2. Work out which tax year the move falls in for each country: the calendar year in the US and Canada, the April-to-April tax year in the UK.
  3. Count your days in each country from your travel records, using each tax authority’s own rules on what counts as a day.
  4. List the ties you keep and the ties you give up: home, partner and children, bank accounts, licences, health cover, memberships.
  5. Tell your clients and any payment platform your new address, and send updated tax forms if they ask for them.
  6. Split your invoices and costs at your move date, and note where you did the work for each client.
  7. Close or update the registrations you no longer need in the country you leave, and register where you need to in the new one.
  8. File the move-year return the way each country asks: a dual-status return in the US, the residence pages with Self Assessment in the UK, or a part-year return in Canada.
  9. If both countries tax the same income, check the treaty between them and claim relief or a foreign tax credit where you can.
  10. Ask an adviser before you move if you own property, shares or other assets, keep a home in the country you leave, or the tests give you different answers.

Whether an invoice counts by the date you issued it or the date you were paid depends on your accounting method: see cash vs accrual.

10. Wording to copy

Replace everything in [brackets]. This is ours, not from any agency, and it's not legal or tax advice. If your bank details change, confirm them with each client by phone: changed bank details are a common scam (see payment scams).

Telling clients you're moving

A move record for your files

11. Checklist

Our summary of the official pages above, not an official checklist.

Free tools and kits

Where the sources differ

When to get advice

Talk to an accountant or a tax adviser in each country involved. This page is general information only.

Sources

Checked 2026-10-18. Found a mistake? Tell us via Support.