Tax residence in the United Kingdom for Pakistani taxpayers

The UK decides residence under the Statutory Residence Test for its tax year of 6 April – 5 April: automatic overseas and UK tests first, then UK ties combined with days in the UK. Pakistan counts its own tax year of 1 July – 30 June, and a Pakistani citizen can stay resident under s. 82(d) with fewer than 183 days. Where both countries claim you, Art. 4(2) of the 1986 Pakistan–UK Convention decides.

Check your status: Pakistan and United Kingdom

Free, no sign-up, about 3 minutes. Conclusion under Pakistan's Income Tax Ordinance, 2001, compared with the law of the United Kingdom and the tax treaty.

When United Kingdom treats you as a tax resident

The UK determines residence under its own Statutory Residence Test (SRT) and for its own tax year — 6 April to 5 April — not Pakistan's tax year (1 July – 30 June).

You spent 183 days or more in the UK in the UK tax year — you are automatically UK resident.
Your only home is in the UK (no home abroad, including in Pakistan, where you spent 30+ days) — under the home test you are UK resident.
Full-time work in the UK for a 365-day period — you are UK resident.
Your UK days combined with your UK ties reach the sufficient ties threshold — you are UK resident even with fewer than 183 days.

When you are a nonresident

You spent fewer days in the UK than any UK test requires (16 or 46) — you are automatically not UK resident.
Full-time work abroad and fewer than 91 days in the UK — under the automatic overseas test you are not UK resident.
Under the sufficient ties test you have too few UK ties for your number of days — you are not UK resident.

Where the rules of the United Kingdom clash with Pakistani tax rules

Collision: Pakistani citizen resident in both countries. Since tax year 2023, s. 82(d) of the Income Tax Ordinance treats a Pakistani citizen as resident in Pakistan if he or she was not present in any other country for more than 182 days in the Pakistani tax year, or is not a resident taxpayer of any other country. The UK SRT can make you UK resident with far fewer days (home test, full-time work, sufficient ties). If both apply, Art. 4(2) of the Pakistan–UK Convention decides: permanent home; if a home in both — centre of vital interests; if that cannot be determined or you have no permanent home in either country — habitual abode; then nationality; then mutual agreement. If the treaty makes you a UK resident, Pakistan may tax you only on Pakistan-source income as the treaty allows. Keep an HMRC certificate of residence and a day count for both tax years.
Collision: the UK treats you as resident with fewer than 183 days. The SRT makes you UK resident with fewer than 183 days — through the home test, full-time work in the UK or the sufficient ties test (family, accommodation, work, previous years). Pakistan may treat you as resident at the same time: 183 days in its own tax year, a government posting abroad (s. 82(c)), or, for a citizen, the s. 82(d) rule. The tie-breaker in Art. 4(2) then decides treaty residence; the order is permanent home → centre of vital interests → habitual abode → nationality → mutual agreement.
Collision: after moving back to Pakistan the UK may still treat you as resident. If you were UK resident in any of the three previous UK tax years, 16 days and 4 ties (or 46 days and 3 ties) are enough to remain UK resident. If you are resident in Pakistan at the same time, Art. 4(2) of the treaty decides — a home kept in the UK can keep you UK resident under the treaty as well. A citizen returning after four non-resident tax years is exempt in Pakistan on foreign-source income in the year of return and the next year (s. 51(1)).

What else to know

Different tax years: 1 July – 30 June and 6 April – 5 April. Pakistan counts days in its tax year (1 July – 30 June); the UK counts days in its tax year (6 April – 5 April). The same stay can give different totals in each country: for example, October to May can be more than 182 days in one Pakistani tax year but split between two UK tax years. The treaty's 183-day employment test (Art. 16(2)) uses any period of 12 months, not either tax year — check every 12-month window that covers your UK work.
Year of arrival or departure: the UK may split its tax year, Pakistan does not. Under specific conditions (moving your home, starting or ending full-time work) the UK splits its tax year and taxes the overseas part as for a non-resident. Pakistan has no split year: status is fixed for the whole 1 July – 30 June tax year. A Pakistani citizen who leaves Pakistan during a tax year and stays abroad for the rest of it is exempt in Pakistan on salary earned abroad in that year (s. 51(2)).
FIG regime: Pakistani income of new UK residents. If you were not UK resident for at least 10 years before arriving, you can claim the FIG regime for up to the first 4 UK tax years: qualifying foreign income and gains — for example rent, profit on debt or gains from Pakistan — are not taxed in the UK, but you lose the income tax and CGT tax-free allowances, and foreign employment income is not covered. Pakistan still taxes Pakistan-source income (s. 101) even if you are a UK resident under the treaty, within the treaty limits.
Working in the UK while resident in Pakistan. If you are resident in Pakistan under the treaty, the UK does not tax your pay for UK work only if all three conditions of Art. 16(2) are met: no more than 183 days in the UK in any period of 12 months, an employer that is not UK resident, and pay not borne by a UK permanent establishment. Otherwise the UK taxes the pay for UK work days. In Pakistan, salary earned abroad is exempt if UK tax on it was withheld by the employer and paid to HMRC (s. 102); otherwise Pakistan gives a credit for UK tax (Art. 23(2), s. 103).
How double tax is relieved between Pakistan and the UK. If you are resident in Pakistan, UK tax on UK-source income is credited against Pakistan tax on that income, up to the share of Pakistan tax attributable to it (Art. 23(2)); under s. 103 the limit is computed separately for each head of income and unused credit is lost. If you are resident in the UK, Pakistan tax on Pakistan-source income is credited against UK tax on the same income (Art. 23(1)). The MLI did not change these paragraphs.
Pakistani government posting to the UK. Federal and Provincial Government employees and officials posted abroad remain resident in Pakistan under s. 82(c). Under Art. 20 of the treaty their government salary is taxable in Pakistan; the UK may tax it only if the person is a UK resident who is a UK national or did not become UK resident solely to render the services. Locally engaged staff of a Pakistani mission who are UK nationals fall under that exception.
Social security: no Pakistan–UK agreement. Pakistan is not on HMRC's list of countries with a social security agreement with the UK. Each country applies its own rules: work in the UK is generally subject to UK National Insurance, and there is no certificate of coverage to exempt you from it on the basis of Pakistani coverage. Social security contributions are outside the income tax treaty.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Islamic Republic of Pakistan for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains (signed at Islamabad on 24 November 1986). The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

Terms you will come across in the United Kingdom

Statutory Residence Test (SRT): the UK test of tax residence: automatic overseas tests, automatic UK tests and the sufficient ties test
UK tax year: 6 April to 5 April — different from Pakistan's tax year of 1 July to 30 June
UK ties: family, accommodation, work, 90-day and country ties counted under the sufficient ties test
split year treatment: splitting the UK tax year of arrival or departure into a UK part and an overseas part
FIG regime: 4-year foreign income and gains regime for new UK residents after 10 years abroad (from 6 April 2025)
HMRC: HM Revenue & Customs, the UK tax authority; it issues UK certificates of residence

Questions

Which tax treaty applies between Pakistan and the UK?

The Convention signed at Islamabad on 24 November 1986, in force since 8 December 1987. The tie-breaker for individuals is Art. 4(2): permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement. The MLI applies to it but did not change Art. 4(2).

I work in the UK for a few months a year. Does the UK tax my salary?

If you are resident in Pakistan under the treaty, the UK does not tax pay for UK work only if you were present no more than 183 days in any 12-month period, your employer is not UK resident and no UK permanent establishment bears the pay (Art. 16(2)). Otherwise the UK taxes it and Pakistan exempts or credits it (s. 102, Art. 23(2)).

Is there a social security agreement between Pakistan and the UK?

No. Pakistan is not on HMRC's list of countries with a social security agreement with the UK, so each country applies its own contribution rules.

Sources

Legislation and official guidance

Finance Act 2013, Sch. 45 (Statutory Residence Test) — You are UK resident if you meet at least one automatic UK test and none of the automatic overseas tests, or if you meet the sufficient ties test. The automatic overseas tests take priority.
Income Tax Act 2007, s. 4(3) — The UK tax year runs from 6 April to the following 5 April.
HMRC RDR3 — Statutory Residence Test guidance — HMRC's official guidance on the Statutory Residence Test.
Sch. 45, paras 12–14 — Automatically non-resident: fewer than 16 days in the UK (if UK resident in any of the 3 previous tax years), fewer than 46 days (if not), or full-time work abroad with fewer than 91 days in the UK and fewer than 31 UK work days.
Sch. 45, paras 22–23 — A day counts if you are in the UK at midnight; transit days do not count; up to 60 days spent in the UK because of exceptional circumstances (war, natural disaster) can be disregarded.
Sch. 45, para 7 — Automatically UK resident: at least 183 days in the UK in the tax year.
Sch. 45, paras 8, 25 — Home test: a UK home where you spent at least 30 days, and no overseas home where you spent at least 30 days (assessed within a 91-day period).
Sch. 45, para 9 — Full-time work in the UK for a 365-day period: on average at least 35 hours a week, with more than 75% of working days in the UK.
Sch. 45, paras 17–19, 31–38 — Sufficient ties test: arrivers — 46–90 days and 4 ties, 91–120 days and ≥3, ≥121 days and ≥2; leavers (UK resident in 1 of the 3 previous years) — 16–45 days and ≥4, 46–90 and ≥3, 91–120 and ≥2, ≥121 and ≥1. Ties: family, accommodation, work, 90-day, country.
Income Tax Ordinance, 2001, s. 82(a) — An individual is a resident individual for a tax year if present in Pakistan for a period of, or periods amounting in aggregate to, 183 days or more in the tax year (1 July – 30 June).
Art. 16(2) Pakistan–UK Convention (1986) — Pay of a resident of one State for employment exercised in the other State is taxable only in the residence State if (a) the employee is present in the other State for a period or periods not exceeding in the aggregate 183 days in any period of 12 months, (b) the pay is paid by or on behalf of an employer who is not a resident of the other State, and (c) it is not borne by a permanent establishment or fixed base of the employer in the other State.
Income Tax Ordinance, 2001, s. 82(d) (inserted by the Finance Act, 2022; consolidated text amended up to 30.06.2026 listed by FBR) — A citizen of Pakistan is also a resident individual if he or she is not present in any other country for more than 182 days during the tax year, or is not a resident taxpayer of any other country. Applies from tax year 2023.
Art. 4(2) Pakistan–UK Convention (1986) — Dual-resident individual: (a) resident of the State where he has a permanent home available to him; if he has one in both States — the State with which his personal and economic relations are closer (centre of vital interests); (b) if that State cannot be determined, or if he has no permanent home available in either State — the State of his habitual abode; (c) habitual abode in both States or in neither — the State of which he is a national; (d) national of both or of neither — the competent authorities settle the question by mutual agreement.
Income Tax Ordinance, 2001, s. 107(2) — Subject to s. 109, a double taxation agreement and its implementing notification have effect notwithstanding anything in any other law, so far as they provide relief from tax under the Ordinance, determine the Pakistan-source income of non-residents, or provide for exchange of information.
Income Tax Ordinance, 2001, s. 51 — (1) A citizen who becomes resident in a tax year after being non-resident in the four preceding tax years: foreign-source income is exempt in that tax year and the following one. (2) A citizen who leaves Pakistan during a tax year and remains abroad for the rest of it: salary earned outside Pakistan in that year is exempt.
Sch. 45, Part 3 (paras 44–51); HMRC RFIG21010 — In the year of arrival or departure the UK tax year may, under specific conditions, be split: the overseas part is taxed as for a non-resident. It is not elective — it applies automatically if the conditions are met.
Finance Act 2025, s. 37; ITTOIA 2005 ss. 845A–845J; GOV.UK «Check if you can claim the 4-year foreign income and gains regime» (published 6 April 2025) — From 6 April 2025 the 4-year foreign income and gains (FIG) regime replaced the remittance basis. Available for at most 4 consecutive tax years from the start of UK residence, after at least 10 years of non-UK residence; claimed on the Self Assessment return; claimants lose the income tax and CGT tax-free allowances. Foreign earnings and specific employment income are not eligible.
Income Tax Ordinance, 2001, s. 101 — Salary is Pakistan-source to the extent it is received from employment exercised in Pakistan (wherever paid) or is paid by or on behalf of the Federal, a Provincial or a Local Government in Pakistan (wherever the employment is exercised). Dividends of resident companies, profit on debt and royalties paid by residents, rent and gains on immovable property in Pakistan, gains on shares of resident companies and pensions paid by residents are Pakistan-source; everything else is foreign-source.
Income Tax Ordinance, 2001, s. 102 — Foreign-source salary received by a resident individual is exempt if the individual has paid foreign income tax on it; tax is treated as paid if it was withheld by the employer and paid to the revenue authority of the country where the employment was exercised.
Art. 23(1)–(2) Pakistan–UK Convention (1986) — UK: Pakistan tax on income or gains from sources within Pakistan is allowed as a credit against UK tax on the same income (para. 1(a)). Pakistan: subject to Pakistani law on foreign tax credit, UK tax on UK-source income of a resident of Pakistan is credited against Pakistan tax on that income, up to the proportion of Pakistan tax that this income bears to the entire income chargeable to Pakistan tax (para. 2).
Income Tax Ordinance, 2001, s. 103 — A resident taxpayer gets a credit for foreign income tax on foreign-source income equal to the lesser of the foreign tax paid and the Pakistan tax on that income (average Pakistani rate × net foreign-source income), computed separately for each head of income; unused credit is not refunded, carried back or forward; the foreign tax must be paid within two years after the end of the tax year.
Synthesised text of the MLI and the 1986 UK–Pakistan Convention (GOV.UK) — MLI in force for the UK from 1 October 2018 and for Pakistan from 1 April 2021; effective for UK income tax from 6 April 2022 and for other Pakistan taxes for taxable periods beginning on or after 1 October 2021. The MLI replaces Art. 4(3) (entities) only; Art. 4(2), Art. 16 and Art. 23(1)–(2) are unchanged. The authentic texts prevail.
Income Tax Ordinance, 2001, s. 82(c) — An individual is a resident individual for a tax year if he or she is an employee or official of the Federal Government or a Provincial Government posted abroad in the tax year — regardless of days in Pakistan.
Art. 20 Pakistan–UK Convention (1986) — Salaries paid by a State (or its subdivision or local authority) for government service are taxable in the paying State, except where the services are rendered in the other State by an individual who is a resident and national of that other State or did not become resident there solely to render the services; government pensions are taxable only in the paying State unless the individual is a resident and national of the other State.
HMRC — Social security abroad (NI38), updated 7 July 2026 — Lists the countries with which the UK has social security agreements (outside the EU co-ordination rules); Pakistan is not among them. Without an agreement, Class 1 contributions can remain due for the first 52 weeks of work abroad if the employer has a UK place of business and the employee is ordinarily resident in the UK.
Art. 4(2)(b) Pakistan–UK Convention — If you have no permanent home available in either State, the treaty goes straight to habitual abode (the centre of vital interests step applies only where there is a home in both States).
Art. 4(2)(a) Pakistan–UK Convention — Centre of vital interests: the State with which your personal and economic relations are closer.
Art. 4(2)(c), (d) Pakistan–UK Convention — Habitual abode in both States or in neither — resident of the State of which you are a national; national of both or neither — the competent authorities settle the question by mutual agreement (Art. 25).

Case law

Court of Appeal (England and Wales), A Taxpayer v HMRC [2025] EWCA Civ 106, 13/02/2025 — Moral obligations (caring for the children of a seriously ill relative) can be taken into account in deciding whether circumstances are exceptional for disregarding days under para 22(4); a person with 50 days was held not UK resident against a threshold of 45.
First-tier Tribunal (Tax Chamber), Michael Parker v HMRC [2026] UKFTT 652 (TC), 01/05/2026 — Three days were treated as transit and one as exceptional circumstances; with 89 remaining UK days the taxpayer met the full-time work abroad test and was not UK resident.

Updated 04/11/2026. The result is for information only and is not tax or legal advice. The FBR, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes with each Finance Act. Consult a qualified adviser before making decisions.

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