Defensible exit planning for Australian high earners relocating to the UK. No vague promises — just the numbers, the rules, and the evidence that holds up.
Every calculation below uses the same assumptions the ExitProof calculator applies when you select "UK" as your destination. These reflect current ATO rules (ITAA36 s6(1), TR 2023/1) and HMRC tax law as of 2024-25. Note: the UK is not a tax haven — at high incomes, UK income tax rates are significant. The case for leaving is weaker here than for Dubai or Singapore.
* On ~£260k AUD salary in UK: effective rate approximately 28–32% after personal allowance (approximately £62k–£72k UK income tax/yr ≈ AUD 115k–135k). Exit CGT on $450k portfolio at 7% growth over pre-departure period: ~$38k. UK saves vs AU at 47% but the advantage is materially smaller than Dubai or Singapore.
* On ~£400k AUD salary: UK income tax approximately £108k–£125k/yr (effective 27–31%). Exit CGT on $800k portfolio: ~$68k. UK income tax is substantial — this is not a tax haven at this income level.
* On ~£700k AUD salary: UK income tax approximately £230k–£265k/yr (effective 33–38%, approaching AU rates). The delta at this income level is driven primarily by CGT: zero non-resident CGT on share gains vs 25% effective AU rate. Exit CGT on $2M portfolio: ~$168k.
Since 2013, the UK uses a 3-part Statutory Residence Test (SRT) to determine tax residency. Unlike Australia's ordinary concepts approach, the SRT is more mechanical — which makes it more predictable but also means you need to track your days carefully.
| Part of SRT | What it tests | Relevance for Australian high earners |
|---|---|---|
| Part 1: Automatic UK residence | Sufficient connection: 183+ days in UK, UK home (sole or main), or full-time work in UK | If you spend 183+ days in UK or work full-time in London, you're automatically UK tax resident |
| Part 2: Automatic non-residence | You were UK tax resident in one of previous 3 years, then spend fewer than 46 days in UK and work overseas | Useful if returning to Australia after a London stint |
| Part 3: Sufficient ties test | If not automatic resident/non-resident, assessed on number of ties (accommodation, family, work, days) | Most complex part — multiple factors assessed against day count thresholds (17–45 days depending on income) |
The SRT replaced the old "ordinarily resident" test. It is significantly more predictable than the ATO's ordinary concepts test but requires meticulous day-count tracking. Reference: HMRC RDRM10000 — Residence: Statutory Residence Test
UK income tax applies to all UK-sourced and remitted foreign income. For a high earner on £300k+ (~$AUD 570k+), the effective tax rate including national insurance is approximately 40–45%. National Insurance Contributions (NICs) apply at 12% on earnings between £12,570 and £50,270, and 2% above £50,270 — adding approximately 2% to the effective rate for high earners. Total tax burden on high UK salaries approaches Australian marginal rates.
UK does not impose CGT on non-residents disposing of non-UK assets. This means your global share portfolio can be managed without UK CGT liability while you're a UK non-resident (under SRT Part 2). However, if you become UK tax resident, you will be subject to UK CGT on worldwide gains at 10% (basic rate) and 20% (higher rate) — not 25%. This is still meaningfully below Australia's effective 25% (marginal rate × 50% discount).
Reference: GOV.UK — Skilled Worker Visa, HMRC RDRM11000
Under s6(1) ITAA36, you are an Australian tax resident if you satisfy any one of four tests. You must fail all four to be a genuine non-resident. London is the most London-centric of all exit destinations — the AU-UK DTA gives you a treaty tie-breaker, but your UK residency must be genuine and the ordinary concepts evidence must be built.
| Test | What it asks | UK-mover risk |
|---|---|---|
| 1. Ordinary concepts | Does your presence in Australia feel "usual and settled" — or temporary and casual? | HIGH — London expat community is large; returning for school holidays and maintaining AU property sustains "continuity of association" |
| 2. Domicile | Is your domicile in Australia? (Presumed yes unless you establish a permanent place of abode overseas AND intend to stay) | HIGH — Australians with lifelong AU domicile face a high bar to establishing UK domicile; "permanent place of abode" test applies |
| 3. 183-day test | Have you been physically present in Australia for 183+ days in the income year? | MEDIUM — if working full-time in London, AU days reduce; but school holidays and family visits add up |
| 4. Superannuation test | Does your employer pay compulsory superannuation contributions in Australia? | LOW — UK employer pays UK NICs, not AU super; verify payroll location |
The AU-UK DTA is comprehensive, long-standing (1967, updated 2002), and provides strong protections. However, it's important to understand that the UK's taxation of high employment income (40–45% at AUD $570k+) means the DTA's tax sparing and credit mechanisms will be most valuable when you've paid UK tax on income that would also have been taxed in Australia.
Each item addresses one of the six ordinary concepts factors (TR 2023/1 para 20). For the UK specifically, domicile evidence is a priority — more than for Singapore or Dubai. Build your evidence file from the day you land.
Headline numbers. Run the full comparison →
| UK | Singapore | Stay in Sydney | |
|---|---|---|---|
| Personal income tax | 20–45% (effective 28–40% for high earners) | 0%–22% (effective 8–16% for high earners) | 37%–47% |
| AU CGT for non-residents | 0% on shares (post-departure) | 0% on shares (post-departure) | N/A |
| DTA with Australia | Yes (comprehensive, tie-breaker) | Yes (comprehensive, tie-breaker) | N/A |
| Evidence burden | High (domicile + ordinary concepts) | Medium (treaty support available) | N/A |
| Capital gains tax for non-residents | 0% (shares); 18–28% (UK residential property) | 0% | 25% effective (with 50% discount) |
| NHS surcharge | £1,035/yr per adult (visa requirement) | N/A (SG healthcare excellent, low cost) | Medicare Levy 2% |
| 10yr leave-vs-stay delta (~$450k earner) | ~+$292k | ~+$737k | Baseline |
UK's delta is primarily driven by CGT savings on investment portfolio (0% vs 25% effective AU rate), not income tax savings. At very high incomes, the income tax advantage vs Australia narrows significantly. Run your personalised comparison →
