Taxes for American Expats Living in United Kingdom
American expats in the UK must comply with tax rules from both Her Majesty’s Revenue and Customs (HMRC) and the Internal Revenue Service (IRS). This requires careful navigation of each system’s requirements.
Residency status in the UK, determined by the Statutory Residence Test (SRT), impacts your UK tax obligations. If you spend 183 days or more in the UK, you’re typically considered a UK resident for tax purposes.
The UK tax system applies progressive rates (20%, 40%, and 45%) based on income, with important deadlines like the January 31st self-assessment deadline for filing returns. Income taxes are withheld through the PAYE system for employees.
Expats pay National Insurance contributions based on employment status, which entitles them to state benefits and pensions.
Despite living abroad, US citizens must still file a US tax return and report worldwide income. The Foreign Earned Income Exclusion (FEIE) and Foreign Tax Credit (FTC) are tools to mitigate double taxation.
US expats must file an FBAR and possibly Form 8938 if they hold foreign financial accounts or assets exceeding certain thresholds
The US-UK tax treaty helps prevent double taxation by clarifying tax rights for different income types. The Totalization Agreement ensures that expats don’t pay social security taxes in both countries.
Specialized tax services are essential for navigating both US and UK tax systems. Universal Tax Professionals offers integrated US and UK tax filing through partnerships with UK tax firms, ensuring seamless tax management and compliance.
HMRC (Her Majesty’s Revenue and Customs) is the UK’s tax authority responsible for collecting taxes and enforcing tax laws. As an American expat in the UK, it’s crucial to understand how HMRC views your residency status, as this will significantly impact your tax obligations.
UK Residency is determined by the Statutory Residence Test (SRT). The SRT considers several factors, including the number of days you spend in the UK and your ties to the country. To be a UK resident for tax purposes, you generally need to meet one of the following criteria:
You spend 183 or more days in the UK in a tax year.
You have your only home in the UK and are present for at least 30 days during the tax year.
You meet specific conditions of the ‘automatic overseas test’ or the ‘automatic UK test’.
Your residency status affects your UK tax obligations, including the need to file a UK tax return and your eligibility for certain tax allowances.
| Tax Rate | Income Range |
| Basic Rate (20%) | Applies to income between £12,571 and £50,270. |
| Higher Rate (40%) | Applies to income between £50,271 and £150,000. |
| Additional Rate (45%) | Applies to income over £150,000. |
Read More: UK Tax Deadline for American Expats
UK Tax Deadlines are crucial to comply with, as missing them can lead to penalties. The key deadlines include:
Self-Assessment Tax Returns: If you are self-employed or need to file a self-assessment tax return, the deadline is January 31st following the end of the tax year.
PAYE (Pay As You Earn): If you are an employee, your employer will handle tax withholding through the PAYE system. Ensure that your employer is correctly deducting taxes from your salary.
The PAYE System is used by employers to withhold income tax and National Insurance contributions from employees’ wages. As an American expat working in the UK, your employer will automatically deduct taxes based on your earnings and tax code.
It’s important to check your tax code regularly to ensure it reflects your correct tax status. If you have any additional income or allowances, you may need to adjust your tax code to avoid over or underpayment of taxes.
The PAYE system operates in real time, meaning your employer deducts tax from your wages throughout the year. Ensure that your employer provides a P60 form by May 31st, following the end of the tax year. This form summarizes your total earnings and the taxes paid.
National Insurance (NI) contributions are a key component of the UK tax system and are essential for accessing state benefits and pensions. As an expat, you will make NI contributions based on your employment status:
National Insurance contributions entitle you to benefits such as healthcare, unemployment benefits, and state pensions. Ensure you understand how these contributions affect your eligibility for benefits and how they are calculated.
As an American expat living in the UK, you have specific US tax obligations that you need to meet, regardless of your residence abroad. The US tax system operates on a citizenship-based model, which means that US citizens are required to file tax returns and report their worldwide income, even if they live outside the United States.
Annual Tax Return: As a US citizen living in the UK, you must file an annual US tax return using Form 1040. This form requires you to report your worldwide income, including wages, interest, dividends, and any other sources of income. The due date for filing your tax return is April 15th, but this deadline is automatically extended to June 15th for expats. However, interest on any tax owed will still accrue from April 15th.
Extension: If you need additional time to file, you can request an automatic extension by filing Form 4868, which extends the deadline to October 15th. This extension is for filing the return, not for paying any taxes owed, so you should estimate and pay any taxes due by the original April deadline to avoid interest and penalties.
Eligibility: The Foreign Earned Income Exclusion (FEIE) allows you to exclude up to a certain amount of your foreign earned income from US taxation. For 2023, the maximum exclusion amount is $120,000 per qualifying individual. To qualify, you must meet either the Bona Fide Residence Test or the Physical Presence Test.
Bona Fide Residence Test This test requires that you live in a foreign country for an uninterrupted period that includes an entire tax year and demonstrate that you are a bona fide resident of that country.
Physical Presence Test You must be physically present in a foreign country for at least 330 full days during a 12-month period.
Purpose: The Foreign Tax Credit allows you to offset your US tax liability by the amount of foreign taxes paid on the same income. This helps to prevent double taxation on income earned abroad.
Claiming the Credit: To claim the FTC, you must file Form 1116. You need to provide details of the foreign taxes paid and the income on which these taxes were levied. The credit can be applied to income taxes paid to foreign governments and is subject to certain limits.
Requirement: If you have financial accounts outside the US with an aggregate value exceeding $10,000 at any time during the calendar year, you must file the Foreign Bank Account Report (FBAR) using FinCEN Form 114. This requirement is separate from your income tax return and is submitted electronically through the Financial Crimes Enforcement Network (FinCEN) website.
Read More: 5 Things to know about FBAR
Form 8938: In addition to the FBAR, US expats may need to file Form 8938, Statement of Specified Foreign Financial Assets, as part of their annual tax return. This form reports foreign assets such as bank accounts, stocks, and securities, exceeding certain thresholds. For individuals living abroad, the reporting thresholds are $200,000 for single filers and $400,000 for married couples filing jointly.
Penalties: Failure to file Form 8938 can result in substantial penalties, including a $10,000 penalty for not disclosing the required information and additional penalties for continued non-compliance.
Purpose: The US-UK tax treaty is designed to alleviate the issue of double taxation by determining how different types of income, such as dividends, interest, and royalties, should be taxed by each country. The treaty provides guidelines on which country has taxing rights over various types of income and allows for credits and exemptions to avoid being taxed twice on the same income.
Impact on Filing: Understanding the provisions of the treaty can help you correctly apply for treaty benefits, such as reduced tax rates on certain types of income. You may need to provide additional documentation to claim treaty benefits, such as Form 8833, Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b).
Totalization Agreement: The US and the UK have a Totalization Agreement to avoid double social security taxation for expatriates. This agreement ensures that you do not pay social security taxes to both countries on the same earnings. Under this agreement, you are generally required to pay social security taxes only to the country where you are employed, provided you meet specific criteria.
Exemptions and Contributions: If you are employed in the UK, you typically pay National Insurance contributions rather than US Social Security taxes. However, if you are self-employed, you may need to ensure that you are meeting your obligations under both systems, which may involve additional filings or adjustments to your contributions.
UK Tax Deadlines are crucial to comply with, as missing them can lead to penalties. The key deadlines include:
US Tax Preparation and Filing: Expat tax services ensure that your US tax returns are filed correctly and on time. This includes preparing Form 1040 and any additional forms required for expatriates, such as Form 1116 for claiming the Foreign Tax Credit or Form 2555 for the Foreign Earned Income Exclusion. Tax professionals will help you understand and apply for available exclusions, credits, and treaty benefits to minimize your US tax liability.
Tax Planning and Advice: Strategic tax planning is crucial for expats to manage their tax liabilities effectively. Expat tax services provide personalized advice on how to structure your income and investments to take full advantage of tax treaties, exclusions, and credits. This can also include retirement planning and estate tax considerations for expatriates.
At US Tax Preparation and Filing, we understand the unique challenges faced by American expats in the UK. Our firm offers comprehensive tax services designed to address both US and UK tax obligations seamlessly. By partnering with a UK tax firm, we provide a one-stop solution for managing your tax affairs across both jurisdictions.
US Tax Expertise: Our team of experienced tax professionals specializes in US expatriate tax issues. We manage all required reporting, including FBAR and Form 8938, ensuring that you meet all disclosure requirements for both US and UK tax authorities. Our expertise in handling these forms helps you avoid potential penalties and ensures compliance with international tax regulations.
UK Tax Partnership: Through our partnership with a UK tax firm, we offer expert assistance with your UK tax matters. This collaboration ensures that your UK tax returns are handled by professionals who are well-versed in UK tax laws and regulations.
Streamlined Process: By working with Universal Tax Professionals and our UK tax partners, you benefit from a coordinated approach to your tax needs. We handle your US tax filings while our UK partners address your UK tax responsibilities. This integrated service simplifies the tax process, reduces the risk of errors, and ensures that both sets of tax obligations are managed efficiently.
Personalized Support: Our approach is tailored to your individual needs, whether you are a US citizen living in the UK, an expat working in multiple countries, or someone with complex tax situations. We offer personalized support to help you with your tax responsibilities and provide proactive advice on how to optimize your tax situation.
