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
- 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.
- 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.
- US citizens are different: moving abroad doesn't end US tax on your worldwide income or your US filing.
- 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.
- If two countries both treat you as resident, the tax treaty between them has tie-breaker rules.
- 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
- 2. The year you arrive in or leave the US
- 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
- 7. Resident in two countries
- 8. Side by side
- 9. Step by step
- 10. Wording to copy
- 11. Checklist
- Free tools and kits
- Where the sources differ
- When to get advice
- Related
- Sources
1. United States: the IRS tests
- Two tests: "If you are not a U.S. citizen, you are considered a nonresident of the United States for U.S. tax purposes unless you meet one of two tests. You are a resident of the United States for tax purposes if you meet either the green card test or the substantial presence test for the calendar year (January 1 – December 31)." (IRS: Determining an individual's tax residency status, page date 11-Feb-2026).
- Substantial presence: "You will be considered a United States resident for tax purposes if you meet the substantial presence test for the calendar year." "To meet this test, you must be physically present in the United States (U.S.) on at least:"
- 31 days during the current year, and
- 183 days during the 3-year period that includes the current year and the 2 years immediately before that, counting:
- All the days you were present in the current year, and
- 1/3 of the days you were present in the first year before the current year, and
- 1/6 of the days you were present in the second year before the current year.
- What counts as a day: "You are treated as present in the U.S. on any day you are physically present in the country, at any time during the day." "Do not count the following as days of presence in the U.S. for the substantial presence test:"
- Days you commute to work in the U.S. from a residence in Canada or Mexico if you regularly commute from Canada or Mexico.
- Days you are in the U.S. for less than 24 hours, when you are in transit between two places outside the United States.
- Days you are in the U.S. as a crew member of a foreign vessel.
- Days you are unable to leave the U.S. because of a medical condition that develops while you are in the United States.
- Days you are an exempt individual (see below).
- Closer connection: "Even if you met the substantial presence test, you can still be treated as a nonresident of the United States for U.S. tax purposes, within Internal Revenue Code Section 7701(b)(1)(B), if you:"
- Were present in the United States less than 183 days during the year, and
- Had a closer connection during the year to one foreign country in which you had a tax home than to the United States (unless you had a closer connection to two foreign countries, discussed next), and
- Maintained a tax home in that foreign country during the entire year (see Chapter 28 of Publication 17 for a discussion of the tax home concept), and
- Had not taken steps toward, and did not have an application pending for, lawful permanent resident status (green card).
- US citizens: "If you are a U.S. citizen or resident alien, the rules for filing income, estate, and gift tax returns and paying estimated tax are generally the same whether you are in the United States or abroad. You are subject to tax on worldwide income from all sources and must report all taxable income and pay taxes according to the Internal Revenue Code." "Many Americans living abroad qualify for special tax benefits, such as the foreign earned income exclusion and foreign tax credit, but they can only get these benefits by filing a relevant U.S. return." (IRS: U.S. citizens and resident aliens abroad, page date 28-Sep-2026). This page doesn't go into those benefits.
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
- Both in one year: "You can be both a nonresident and a resident for U.S. tax purposes during the same tax year. This usually occurs in the year you arrive or depart from the United States. If so, you need to file a dual-status income tax return."
- What dual status means: "You are a dual-status individual when you have been both a U.S. resident and a nonresident in the same tax year." "The most common dual-status tax years are the years of arrival and departure." "For the part of the year you are a U.S. resident, you are taxed on income from all sources." "For the part of the year you are a nonresident, you are taxed on income from U.S. sources only." (IRS: Taxation of dual-status individuals, page date 23-Nov-2025).
- Which return: "You must file Form 1040, U.S. Individual Income Tax Return, if you are a dual-status taxpayer who becomes a U.S. resident during the year and who is a resident of the U.S. on the last day of the tax year." "You must file Form 1040-NR, U.S. Nonresident Alien Income Tax Return, if you are a dual-status taxpayer who gives up residence in the United States during the year and who is not a U.S. resident on the last day of the tax year."
- One restriction among several: "You cannot use the standard deduction allowed on Form 1040, U.S. Individual Income Tax Return. However, you can itemize certain allowable deductions."
- When residency starts: "If you meet the substantial presence test for a calendar year, your residency starting date is generally the first day you are present in the United States during that calendar year." (IRS: Residency starting and ending dates, page date 14-Mar-2026).
- When residency ends: "Under the general rule, the residency ending date is December 31 of the calendar year in which you left the United States." "However, your residency ending date is the last day during the calendar year that you are physically present in the United States if, for the remainder of the calendar year:"
- your tax home is in a foreign country (cf. Rev. Rul. 93-86); and
- you maintain a closer connection to that foreign country than to the United States (cf. Treas. Reg. § 301.7701(b)-2(d)).
- Coming back the next year: "Caution! If you were a U.S. resident for any part of the current year, and you were a U.S. resident during any part of the following year, you will be taxed as a U.S. resident through the end of the current year."
For how US freelancers report business income, see Schedule C for US freelancers.
3. United Kingdom: the statutory residence test
- Why it matters: "Your UK residence status affects whether you need to pay tax in the UK on your foreign income." "Non-residents only pay tax on their UK income - they do not pay UK tax on their foreign income." "Residents normally pay UK tax on all their income, whether it’s from the UK or abroad." "Whether you’re UK resident usually depends on how many days you spend in the UK in the tax year (6 April to 5 April the following year)." (GOV.UK: Tax on foreign income, UK residence and tax, page date 2014-12-08).
- One year at a time: "The test allows you to work out your residence status for a tax year. Each tax year is looked at separately, so you may be resident in the UK in one year but not the next, or vice versa." "If you’ve been in the UK for 183 or more days you’ll be a UK resident. There is no need to consider any other tests." (HMRC: RDR3: Statutory Residence Test (SRT) notes, page date 2026-06-11).
- The order of the tests: "Take the following steps to find out your residence status under the SRT:"
- If you’ve been in the UK for less than 183 days in the tax year go to step 2.
- If you meet any of the automatic overseas tests you will not be resident in the UK for that tax year. If you do not meet any of these tests go to step 3.
- If you meet any of the automatic UK tests or the sufficient ties test, you will be UK resident for that tax year. If you do not meet any of these tests you will not be UK resident for that tax year.
- Automatic overseas tests: "You’ll be non-UK resident for the tax year if you were resident in the UK for one or more of the 3 tax years before the current tax year, and you spend fewer than 16 days in the UK in the tax year." "You’ll be non-UK resident for the tax year if you were resident in the UK for none of the 3 tax years before the current tax year, and spend fewer than 46 days in the UK in the tax year." "You’ll be non-UK resident for the tax year if you work full-time overseas over the tax year and:"
- you spend fewer than 91 days in the UK in the tax year
- the number of days on which you work for more than 3 hours in the UK is less than 31
- there is no significant break from your overseas work
- A UK home: "You’ll be UK resident for the tax year if you have, or have had, a home in the UK for all or part of the year and the following all apply:"
- there is or was at least one period of 91 consecutive days when you had a home in the UK
- at least 30 of these 91 days fall in the tax year when you have a home in the UK and you’ve been present in that home for at least 30 days at any time during the year
- at that time you had no overseas home, or if you had an overseas home, you were present in it for fewer than 30 days in the tax year
- Ties: "If you were not UK resident in any of the 3 tax years before the one you are considering, you’ll need to check if you have any of the following:"
- a family tie
- an accommodation tie
- a work tie
- a 90 day tie
- Checking: "If you’re still unsure about your status, you can use the residence status checker. This will give you an indication of whether you were a UK resident during a tax year." "Your status can change from one tax year to the next."
4. The year you arrive in or leave the UK
- Split-year treatment: "When you move in or out of the UK, the tax year is usually split into 2 - a non-resident part and a resident part. This means you only pay UK tax on foreign income based on the time you were living here." "You will not get split-year treatment if you live abroad for less than a full tax year before returning to the UK. You also need to meet other conditions."
- The cases: "You’ll be resident in the UK for the whole of a tax year, but that year may be split into a UK and an overseas part." "If, in a year in which you are UK resident, there is an actual or deemed departure from the UK, then you will need to consider whether any of the split year cases 1 to 3 apply." "If, in a year in which you are UK resident, there is an actual or deemed arrival in the UK then you will need to consider whether any of the split year cases 4 to 8 apply." "You must consider all cases of split year that might apply to you. Each has its own set of conditions, and you need to meet all those conditions for the case to apply." We didn't read the conditions of each case.
- Telling HMRC you're leaving: "You must tell HM Revenue and Customs (HMRC) if any of the following apply, you’re:"
- leaving the UK to live abroad permanently
- going to work abroad full-time (including for a UK-based employer) for at least one full tax year
- a foreign national leaving the UK
- commercial software
- help from a professional, such as an accountant
- The residence pages: "Use supplementary pages SA109 to record your residence and domicile status on your SA100 Tax Return." (HMRC: Residence and foreign income and gains (FIG) regime etc (Self Assessment SA109), page date 2026-09-28). See also UK Self Assessment for freelancers.
- After you leave: "You may be non-resident the day after you leave the UK - this depends on your situation and how ‘split year treatment’ applies to you." "You usually have to pay tax on your UK income even if you’re not a UK resident." "You usually have to send a Self Assessment tax return if you live abroad and:"
- you rent out property in the UK
- you work for yourself in the UK
- you have taxable savings interest from UK banks or building societies
- you have a pension outside the UK and you were UK resident in one of the 5 previous tax years
- Coming back: "If you return to the UK after a period of temporary non-residence, you may need to pay tax in the year you return on certain income and gains you received, or remitted to the UK, during that period."
- Arriving after a long time abroad: "On 6 April 2025 the 4-year foreign income and gains regime replaced the remittance basis. If you make a claim under the regime, you’ll not pay tax on your eligible foreign income and gains." "You’re a qualifying resident if you’re:"
- a UK (England, Scotland, Wales and Northern Ireland) tax resident under the statutory residence test (SRT)
- still within your first 4 years as a UK tax resident following at least a 10-year period as a non-UK tax resident
- profits of a trade carried on wholly outside the UK
- profits of an overseas property business
- dividends from non-UK resident companies
- interest, such as interest paid on a foreign bank account
- tax-free allowances for Income Tax and Capital Gains Tax
5. Canada: residential ties
- Status first: "Under the Canadian income tax system, your income tax obligations to Canada are based on your residency status." "To determine your residency status, all of the relevant facts in your case must be considered, including residential ties with Canada and the length of time, purpose, intent and continuity of the stay while living inside and outside Canada." (CRA: Determining your residency status, page date 2026-01-20).
- The main ties: "Significant residential ties to Canada include:"
- a home in Canada
- a spouse or common-law partner in Canada
- dependants in Canada
- Long trips away: "The strong trend in decisions of the Courts on this issue is to regard temporary absence from Canada, even on an extended basis, as insufficient to avoid Canadian residence for tax purposes." (CRA: Income Tax Folio S5-F1-C1, Determining an Individual’s Residence Status, page date 2026-01-20).
- Staying without ties: "An individual who has not established sufficient residential ties with Canada to be considered factually resident in Canada, but who sojourns (that is, is temporarily present) in Canada for a total of 183 days or more in any calendar year, is deemed to be resident in Canada for the entire year, under paragraph 250(1)(a)."
- Asking the CRA: the CRA has Form NR73, Determination of Residency Status (Leaving Canada) and Form NR74, Determination of Residency Status (Entering Canada). About the opinion it gives back, the folio says: "This opinion is not binding on the CRA and may be subject to a more detailed review at a later date and supporting documentation may be required at that time."
6. The year you leave or arrive in Canada
- Leaving: "Generally, you are an emigrant for income tax purposes if you meet all the following conditions:"
- You leave Canada to live in another country
- You sever your residential ties with Canada
- The date you become a non-resident: "When you leave Canada to settle in another country, you usually become a non-resident of Canada for income tax purposes on the latest of:"
- the date you leave Canada
- the date your spouse or common-law partner and dependants leave Canada
- the date you become a resident of the country you settle in
- Your return for that year: "Enter your date of departure from Canada on page 1 of your return in the "Residence Information" area." "You have to report your world income (in Canadian dollars) for the part of the year that you were considered a resident of Canada." "After you leave Canada, as a non-resident, you pay Canadian income tax only on your Canadian source income."
- Departure tax: "When you leave Canada, you are considered to have sold certain types of property (even if you have not sold them) at their fair market value (FMV) and to have immediately reacquired them for the same amount. This is called a deemed disposition and you may have to report a capital gain (also known as departure tax)."
- Payers and banks: "If you still have bank accounts in Canada or amounts being paid to you from Canada, you are required to notify any Canadian payers and your financial institutions that you are no longer a resident of Canada."
- Arriving: "You become a resident of Canada for income tax purposes when you have enough residential ties in Canada. For most newcomers, this starts the first day you live in Canada." "Where an individual enters Canada and establishes residential ties with Canada as described in ¶1.25 and 1.26, the individual will generally be considered to have become a resident of Canada for tax purposes on the date the individual entered Canada (but see ¶1.32 for comments on sojourners)."
- Your first return: "Enter the date that you became a resident of Canada for income tax purposes." For the part of the year before you arrived: "You have to report certain types of income that you earn in Canada. The most common types of income include:"
- income from employment in Canada or from business carried on 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
- Treaty residence can differ: "Tax residency determined under the residency article of a tax treaty may differ from the residency provisions of the Internal Revenue Code." (IRS, section two).
- Tie-breakers: "Where an individual is determined to be a dual resident, the Residence article in the tax treaty will provide tie-breaker rules to determine in which country the individual will be resident for purposes of the other provisions of the treaty." (CRA folio, section five).
- Canada's side of it: the CRA says that if you keep ties but a treaty makes you resident elsewhere, you may be a deemed non-resident (section six).
- Tax paid twice: relief for foreign tax and the foreign tax credit are covered, for US tax, in our guide for non-US freelancers with US clients. We didn't read the treaties themselves.
8. Side by side
Our summary of sections one to seven, not official wording.
| Question | United States | United Kingdom | Canada |
|---|---|---|---|
| Who this row is about | Someone who is not a US citizen moving to or from the US | Anyone moving to or from the UK | Anyone moving to or from Canada |
| The main test | The green card test or the substantial presence test, which counts days in the current year and the two years before | The statutory residence test: the automatic overseas tests, the automatic UK tests, then the sufficient ties test | Residential ties and all the facts; a long enough stay without ties can make you a deemed resident |
| Tax year it looks at | The calendar year | The UK tax year, which runs from April to April | The calendar year |
| The year you move | Often a dual-status year: income from all sources while resident, US-source income only while not | Resident for the whole year, unless split-year treatment splits it into a UK part and an overseas part | Part-year resident: world income while resident, certain Canadian income for the rest of the year |
| Leaving | Residency 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 income | Tell HMRC; if you file Self Assessment, use the residence pages | Usually 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 |
| Arriving | Residency usually starts on the first day you are in the US in the year you pass the substantial presence test | Split-year cases for arrivals; the foreign income and gains regime for some new residents | Usually 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 authority | The closer connection statement form, and a statement for an early residency ending date | HMRC’s residence status checker gives an indication only | Residency determination forms for leaving or entering; the opinion isn’t binding on the CRA |
| Records to keep | Travel dates and a day count for each calendar year | Days in the UK, days worked, homes and ties for each UK tax year | Move 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.
- Write down the day you plan to leave and the day you plan to arrive, and keep proof of both.
- 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.
- Count your days in each country from your travel records, using each tax authority’s own rules on what counts as a day.
- List the ties you keep and the ties you give up: home, partner and children, bank accounts, licences, health cover, memberships.
- Tell your clients and any payment platform your new address, and send updated tax forms if they ask for them.
- Split your invoices and costs at your move date, and note where you did the work for each client.
- Close or update the registrations you no longer need in the country you leave, and register where you need to in the new one.
- 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.
- If both countries tax the same income, check the treaty between them and claim relief or a foreign tax credit where you can.
- 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
Subject: My new address from [date]
Hi [first name],
A quick note: I'm moving from [country] to [country]. From [date], my business address will be:
[new address]
My work for you carries on as usual. My bank details for payments [are not changing / will change, and I'll confirm the new ones by phone before your next payment].
If your team needs an updated tax form or new details for your records, tell me and I'll send them.
Thanks,
[your name]
[your business name, if any]
A move record for your files
Move record (for my files)
Leaving: [country], last day there: [date]
Arriving: [country], first day there: [date]
Days in [country] this tax year: [number], counted from [travel records]
Days in [country] this tax year: [number], counted from [travel records]
Home in [country] kept or given up: [kept / given up on date]
Partner and children moved: [yes, on date / no / not applicable]
Accounts, licences and memberships changed: [list, with dates]
Clients told of the new address: [client names, dates]
Residence forms or statements filed: [none / form, date]
Adviser consulted: [none / name, date]
Next check: [date]
11. Checklist
Our summary of the official pages above, not an official checklist.
- Your move dates and proof of them (tickets, lease or sale papers, a new address registration)
- A day count for each country for each tax year around the move
- A list of ties you kept and gave up, with dates
- Invoices and costs split at your move date
- Where you did the work for each client before and after the move
- Any residence forms or statements you filed, and any replies
- Values of property you owned on the move date, if a country asks for them
- Each country’s return for the year you moved, and your working
Free tools and kits
- Our free invoice generator runs in your browser and works in any currency, so you can put your new address on invoices; nothing you type is sent or saved.
- Our paid Freelance Billing Kit by Small Rows (US$12, one-time) keeps dated records you can split at your move date: the Invoices tab lists each invoice's issue date, amount paid and paid date, the Expenses tab logs each cost by date, and the Tax Set-Aside tab totals what you received in each month of the calendar year set on Settings. Each file uses one currency label and doesn't convert between currencies. It doesn't count your days in each country, decide where you're tax resident, split a tax year, or file anything.
- All three kits together: the All-Kits Bundle by Small Rows (US$24, one-time).
Where the sources differ
- The UK home test, short and long versions: the GOV.UK summary describes it as "your only home was in the UK for 91 days or more in a row - and you visited or stayed in it for at least 30 days of the tax year", while HMRC's guidance note adds a condition about any overseas home (section three). Go by the guidance note.
- Telling HMRC by post: the GOV.UK leaving page says to send the residence pages by post and that HMRC's online services can't be used, yet also lists commercial software. That page carries a page date from years ago in its metadata; check the current SA109 notes or ask HMRC how to file.
- New UK residents and freelance profits: the foreign income and gains regime lists profits of a trade carried on wholly outside the UK. Our reading is that a freelancer who keeps working from the UK after arriving probably doesn't have such a trade; check with an adviser before you claim.
- The US ending date: the IRS general rule ends residency on the last day of the calendar year, and an earlier date needs a foreign tax home, a closer connection and a statement. Our reading is that without the statement you should expect to be treated as resident to the end of the year.
- Old page dates: the GOV.UK residence and leaving pages carry a page date from years ago in their metadata, and the page on UK income for people living abroad is also several years old. The CRA folio's page carries a date from this year, but it says "This updated Chapter, which may be referenced as S5-F1-C1, is effective November 26, 2015." The text we quote may have been updated since.
- What we did not check: the conditions of each UK split-year case, the definitions of the UK ties and the day-count tables; the US green card test, the first-year choice, the IRS tax guides for aliens and for citizens abroad, the foreign earned income exclusion and foreign account reporting; the treaties' residence articles; social security, National Insurance and Canada Pension Plan when you move; sales tax registrations after a move; US states, provinces and Quebec; other countries' rules.
When to get advice
- you could be resident in two countries in the same year, or the tests give different answers;
- you are a US citizen or a green card holder moving abroad, or moving to the US;
- you own a home, shares or other property in the country you're leaving;
- you might come back to the country you left within a few years;
- your partner or children move at a different time from you;
- you keep working for clients in the country you've left, or work in several countries.
Talk to an accountant or a tax adviser in each country involved. This page is general information only.
Related
- Non-US freelancer with US clients: the form they ask for, withholding and tax credits
- How to invoice international clients
- Closing your freelance business: final tax steps
- UK Self Assessment for freelancers
- Canadian self-employment statement for freelancers
- Schedule C for US freelancers
- Cash vs accrual accounting for freelancers
Sources
- United States: IRS: Substantial presence test (page date 14-Mar-2026) · IRS: Determining an individual's tax residency status (page date 11-Feb-2026) · IRS: Residency starting and ending dates (page date 14-Mar-2026) · IRS: Taxation of dual-status individuals (page date 23-Nov-2025) · IRS: Closer connection exception (page date 16-Jul-2026) · IRS: U.S. citizens and resident aliens abroad (page date 28-Sep-2026)
- United Kingdom: GOV.UK: Tax on foreign income, UK residence and tax (page date 2014-12-08) · HMRC: RDR3: Statutory Residence Test (SRT) notes (page date 2026-06-11) · GOV.UK: Tax if you leave the UK to live abroad (page date 2014-12-08) · GOV.UK: Tax on your UK income if you live abroad (page date 2016-06-08) · HMRC: Residence and foreign income and gains (FIG) regime etc (Self Assessment SA109) (page date 2026-09-28) · GOV.UK: Check if you can claim the 4-year foreign income and gains regime (page date 2025-04-06)
- Canada: CRA: Determining your residency status (page date 2026-01-20) · CRA: Leaving Canada (emigrants) (page date 2026-09-17) · CRA: Newcomers to Canada and the CRA (page date 2026-08-03) · CRA: Completing your return for newcomers (page date 2026-09-17) · CRA: Income Tax Folio S5-F1-C1, Determining an Individual’s Residence Status (page date 2026-01-20)
Checked 2026-10-18. Found a mistake? Tell us via Support.