Moving to or from Scotland mid year: which rates apply

Q: What else changes in the year of the move?

Marriage Allowance. A recipient who becomes a Scottish taxpayer must not be liable above the intermediate rate for the year, a lower limit than in England. See Marriage Allowance for Scottish taxpayers. Pension relief at source. Schemes give relief by reference to Scottish status, and higher Scottish rates may mean extra relief to claim; see Scottish taxpayers and pension relief at source. Marginal rates. Scottish bands change where 42% starts, which interacts with National Insurance; see marginal tax rates for Scottish taxpayers. Moves to or from Wales. The Government of Wales Act 2006 uses the same structure in sections 116E to 116H; see who is a Welsh taxpayer.

You cannot be a Scottish taxpayer for part of a tax year. If you move home between Scotland and another part of the UK, you pay Scottish rates on all your wages, pension and other non savings income for the whole year if your main place of residence was in Scotland for more of the year than it was in each other part of the UK, and you pay the rest of UK rates for the whole year if it was not. Counting nights only decides the question when no main place of residence can be identified.

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Can you be a Scottish taxpayer for only part of the year?

No. HMRC’s Scottish Taxpayer Technical Guidance at STTG4100 says that once someone is identified as a Scottish taxpayer that status applies for a whole tax year, and it is not possible to be a Scottish taxpayer for part of a tax year. The same point appears in the PAYE Manual at PAYE100035.

That has a consequence many people do not expect. Someone who moves from England to Scotland in July and ends up a Scottish taxpayer pays Scottish rates on the salary they earned in England in April, May and June as well. GOV.UK says the new rate is backdated to the start of the tax year on 6 April in which you moved. Savings interest and dividends are unaffected either way, because Scottish taxpayers pay the same tax as the rest of the UK on that income.

The only exception is the year someone arrives in or leaves the UK. STTG4100 notes that split year treatment under the statutory residence test still applies, so a person who arrives from abroad partway through the year and lives in Scotland pays Scottish rates only on income after arrival. See the statutory residence test.

How does the close connection test work for a house move?

Section 80D of the Scotland Act 1998 makes someone a Scottish taxpayer if they are UK resident and have a close connection with Scotland. Section 80E(3) covers anyone with two or more places of residence in the UK during the year, and STTG4400 confirms that includes someone who moves from one single home to another. They have a close connection with a part of the UK if:

for at least part of the year their main place of residence was there;
the times when their main place of residence was there add up to more of the year than the times it was in each other part of the UK, considered separately; and
for at least part of the year they lived at a place of residence there.

HMRC’s example is Donovan, who rents in Birmingham and on 30 June buys a flat in Aberdeen and moves in. His home was in Scotland for longer than in England, so he is a Scottish taxpayer for the whole year. Reverse the move with the same dates and he is not.

The comparison is with each part of the UK separately, not with the rest of the UK combined. In HMRC’s example Emily lives in Fort William for 125 days, Swansea for 115 days and London for 115 days. She spent less than half the year in Scotland but is still a Scottish taxpayer, because 125 days beats each of the other two parts on its own.

A note on the wording

STTG4400 describes the test as the main place of residence being in Scotland for “at least as long” as in each other part. The statute was amended by the Wales Act 2014 with effect from 24 July 2018 and now says “more of the year than”. On a genuine tie the statutory wording means neither part wins on close connection; HMRC’s PAYE100035 says its system treats a tie as the last region the person lived in.

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Where does the halfway point fall in 2026 to 2027?

The 2026 to 2027 tax year runs from 6 April 2026 to 5 April 2027, which is 365 days. For a simple move from one home to another, the date of the move largely decides the answer.

Move from England to Scotland on	Days with home in England	Days with home in Scotland	Result for 2026 to 2027
1 September 2026	148	217	Scottish taxpayer for the whole year
5 October 2026	182	183	Scottish taxpayer, by one day
1 December 2026	239	126	Not a Scottish taxpayer; Scottish from 6 April 2027 if still there

Illustration only. The days are counted from the move date, treating the new home as the main place of residence from that day. Real moves are rarely that tidy. If you buy in Scotland before selling in England and live in both for a while, the question for that overlap is which home was your main place of residence, which is a judgement about family, possessions, registrations and where you actually live, not a count of nights. STTG4400 stresses that this is a qualitative test.

When does counting days decide it instead?

Day counting is a fallback, not the main test. Under section 80D(3) it applies only if the person does not have a close connection with England, Wales or Northern Ireland, and they are then a Scottish taxpayer if they spend more days of the year in Scotland than in any other part of the UK. Section 80F counts where the person is at the end of each day, ignoring days in transit where they arrive and leave the next day without doing anything substantially unrelated to the journey.

STTG4500 gives the typical cases: a consultant with no home who stays in hotels around the UK, a couple with homes in many places where no main one can be identified, and an offshore worker whose rig and work accommodation are not places of residence. Days on the UK continental shelf do not count as days in any part of the UK. Someone between homes who spends the gap in short term lets may need to consider whether those lets were places of residence at all.

What happens to your tax code after a move?

GOV.UK says you must tell HMRC your new address if you move to or from Scotland, and that you may pay tax at the wrong rate if you do not. HMRC’s change of address service through the personal tax account can be used once you have moved.

PAYE100035 explains that HMRC records a Scottish main place of residence start date, or an end date when someone leaves, and then issues codes with or without the S prefix. GOV.UK says tax taken from wages or pension is adjusted automatically so the right amount is paid across the year; with a cumulative code that adjustment arrives in the next pay run. If you file a Self Assessment return, the online return has a box to tell HMRC you pay Scottish Income Tax. For the payroll side, see payroll for Scottish and Welsh employees.

Because the answer depends on where you lived for the whole year, a code issued soon after a move is HMRC’s working assumption. If your plans change, for example you move back before the end of the year, update your address again; the status for the year follows the facts, and HMRC’s end of year reconciliation corrects the tax.

What else changes in the year of the move?

Marriage Allowance. A recipient who becomes a Scottish taxpayer must not be liable above the intermediate rate for the year, a lower limit than in England. See Marriage Allowance for Scottish taxpayers.
Pension relief at source. Schemes give relief by reference to Scottish status, and higher Scottish rates may mean extra relief to claim; see Scottish taxpayers and pension relief at source.
Marginal rates. Scottish bands change where 42% starts, which interacts with National Insurance; see marginal tax rates for Scottish taxpayers.
Moves to or from Wales. The Government of Wales Act 2006 uses the same structure in sections 116E to 116H; see who is a Welsh taxpayer.

What mistakes do people make?

Expecting Scottish rates to start from the moving date. The status covers the whole year or none of it.
Comparing time in Scotland with time in the rest of the UK combined, instead of with each part separately.
Counting nights when there is a clear main home. Day counting applies only where no close connection exists.
Treating the employer’s location as decisive. HMRC’s examples confirm it is irrelevant.
Relying on a capital gains tax main residence election. STTG3100 says it does not decide main place of residence for this purpose.
Not updating the address with HMRC, which leaves the wrong code running and builds up an underpayment or overpayment.

For the full status rules, including students, second homes and parliamentarians, see who is a Scottish taxpayer.

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Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 24 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.