UK → UAE

Moving your business from the UK to Dubai: what HMRC still looks at

Short answer

Leaving the UK does not end UK residence on its own. HMRC's Statutory Residence Test decides it, year by year.

If you come back within 5 years, some income and gains from your time away can still be taxed.

By Sawan Kumar, Chartered Accountant (ICAI), Dubai. Facts checked against the linked sources on 2026-11-03.

The automatic tests

  • You are UK resident if you spend 183 days or more in the UK in the tax year. Source
  • You are non-resident with fewer than 16 UK days, if you were UK resident in any of the previous 3 tax years. Source
  • You are non-resident with fewer than 46 UK days, if you were not UK resident in any of the previous 3 tax years. Source
  • Full-time work overseas can also make you non-resident. Your UK days must stay under 91. Source
  • With full-time overseas work, days you work over 3 hours in the UK must stay under 31. Source
  • If no automatic test settles it, the sufficient ties test in RDR3 section 4 applies. Source

The temporary non-residence trap

  • It can apply if you were UK resident in 4 or more of the 7 tax years before you left. Source
  • It applies if your time as a non-resident lasts 5 years or less. Source
  • Income and gains in scope include capital gains and distributions from closely controlled companies. Source

The UAE side of the move

  • Most mainland companies can now be 100% foreign owned. Some activities of strategic importance can still carry limits. Source
  • UAE Corporate Tax is 0% on taxable income up to AED 375,000 and 9% above that. Source
  • A Qualifying Free Zone Person pays 0% on Qualifying Income. Its other taxable income is taxed at 9%. Source
  • Every taxable business must register for Corporate Tax, including free zone businesses. Source

Common questions

How many days can I spend in the UK after moving to Dubai?

It depends on your history. HMRC's automatic tests use 16 days or 46 days, or 91 days with full-time work overseas.

What if I move back to the UK within 5 years?

Some income and gains received while you were away can be taxed on your return. HMRC's RDR3 guidance lists them.

Sources

  1. HMRC: RDR3 Statutory Residence Test guidance
  2. UAE Government portal: full foreign ownership
  3. UAE Government portal: Corporate Tax
  4. Federal Tax Authority: guide on Free Zone Persons
  5. UAE Ministry of Finance: Corporate Tax

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