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How to fill in SA109 — residence status, split-year treatment and the FIG regime

Form SA109 is the residence supplement to HMRC's Self Assessment return (SA100) — declaring UK residence status when it isn't the standard case: non-resident for the year, mid-split-year, a legacy remittance-basis user, or claiming relief under the new FIG regime that replaced the remittance basis from 6 April 2025.

For 2025–26 the form carries a new name for the same reason — the remittance basis it used to be named for was abolished, and the page was rewritten around the regime that replaced it, though the GOV.UK web address still carries the old title for continuity.

This walkthrough covers the Statutory Residence Test boxes that decide everything else, split-year treatment and its eight statutory Cases, the FIG regime and what's left of the remittance basis for pre-2025 amounts, and the two transitional reliefs — Overseas Workday Relief and the Temporary Repatriation Facility — that only apply for a limited window.

✓ Official source checked 23 August 2026 · GOV.UK last revised this form 6 April 2026SA109 on GOV.UK
Free
United KingdomInformational, not legal or financial adviceOfficial source: GOV.UK
Official form · always current

This is the same official SA109 file HM Revenue & Customs publishes on GOV.UK — the link below fetches the current version live from GOV.UK the moment you click it, so it can never go out of date.

The button gives you Residence and foreign income and gains (FIG) regime etc — current tax year.

Current version: April 2026 · confirmed on GOV.UK 23 August 2026

This walkthrough takes SA109 field by field, in plain English. HMRC's own free online filing service can't take this page at all — anyone who needs SA109 needs commercial software, an agent, or a paper return, which is worth knowing well before the deadline, not on it.

The thing most people get wrong
SA109 cannot be filed as an electronic attachment through HMRC's own free online Self Assessment service — the 2025–26 notes say so directly.

Anyone who needs this page has to buy commercial Self Assessment software, use a professional agent, or file on paper — which pulls the deadline back to 31 October instead of 31 January. Discovering this in late January, after relying on HMRC's free service for the rest of the return, is the single most common way this form derails a filing.
The form, in summary
Valoren
SA1094 pages54 fields guided
With Valoren45 minutes
Without Valoren3–4 hours
working through the day-count and ties, then whichever of the FIG, legacy remittance-basis, OWR and TRF sections actually apply
Deadline
31 Oct / 31 JanSA100 dates — but SA109
can't be e-filed through HMRC's
own free service at all
Who Files
Non-standard residentsor their personal
representative, after death
£
Fee
Freeattaches to
SA100, no fee
Filed with HMRC
Draws from your Estate File
the records this form is built from
PersonalFinancial Accounts·Legal Instruments·Digital Access Map·Asset Inventory·Income & Outgoings·Civil Dossier·Policy Index·Medical Abstract·Property Folio·Succession Plan·Digital Legacy Registry·Business Interests & Directorships·Funeral & Committal Wishes·Dependent Care & Handoff·Personal Record·RegistryMaster Registry·Renewal Register·People, Authority & Contacts·Designated Places·Kinship & Succession Map·SecureAccess Controls·Recovery Routes·Custody & Contingency·EventsDeath & Estate Activation·Incapacity & Medical Proxy·Absence & Continuity Cover·Access Loss & Identity Recovery·Legal Dispute & Evidence Protocol·Theft & Asset Compromise·Property Damage & Incident Response·Relocation & Address Update Protocol·Separation & Custody Documentation·Business Interruption & Continuity·PersonalFinancial Accounts·Legal Instruments·Digital Access Map·Asset Inventory·Income & Outgoings·Civil Dossier·Policy Index·Medical Abstract·Property Folio·Succession Plan·Digital Legacy Registry·Business Interests & Directorships·Funeral & Committal Wishes·Dependent Care & Handoff·Personal Record·RegistryMaster Registry·Renewal Register·People, Authority & Contacts·Designated Places·Kinship & Succession Map·SecureAccess Controls·Recovery Routes·Custody & Contingency·EventsDeath & Estate Activation·Incapacity & Medical Proxy·Absence & Continuity Cover·Access Loss & Identity Recovery·Legal Dispute & Evidence Protocol·Theft & Asset Compromise·Property Damage & Incident Response·Relocation & Address Update Protocol·Separation & Custody Documentation·Business Interruption & Continuity·
Legal basisStatute

SA109 is the residence supplement to the main Self Assessment return (SA100). For 2025–26 it carries a new title — 'Residence and foreign income and gains (FIG) regime etc' — because the page itself changed: the remittance basis of taxation, which the form was previously named for, was abolished from 6 April 2025. The GOV.UK web address still carries the old name for continuity; the form and its notes do not.

The first fourteen boxes work out residence status under the Statutory Residence Test (Finance Act 2013, Sch 45) — a day-count and tie-count mechanism, not a matter of judgment. Everything after that depends on the answer: personal allowances as a non-resident, Double Taxation Agreement relief, the FIG regime for someone newly UK-resident after a long period abroad, and — for anyone still holding pre-6 April 2025 unremitted foreign income or gains — the transitional rules that replaced the remittance basis.

For Valoren's audience specifically, HMRC's own 2025–26 notes address this directly: 'If you're filling in these pages on behalf of someone who died during the 2025 to 2026 tax year, you'll need to read RFIG20900 onwards to help you work out their residence status.' That is a separate guidance path from the standard living-person test — not the same mechanical day-count applied to a shortened year.

Section by section

The form, section by section.

Before you start, you’ll need:
  • Who Files — An individual (or their appointed agent) whose residence position for the year isn't the standard case: someone who was non-UK resident for the whole year, someone who became UK resident partway through it (split-year treatment), a former remittance-basis user with pre-6 April 2025 unremitted foreign income or gains, a 'qualifying new resident' claiming FIG-regime relief, or someone claiming Overseas Workday Relief or non-resident personal allowances under a Double Taxation Agreement. For Valoren's audience: a personal representative completing a deceased person's final Self Assessment return files SA109 when the deceased was non-UK resident, non-domiciled, mid-split-year, or held foreign income, gains or offshore trust interests at death — a common position for an expat estate, a returning-resident estate, or a non-dom estate where Inheritance Tax and income-tax residence questions overlap. HMRC's own notes point preparers in that situation to a separate guidance path (RFIG20900 onwards), not the standard test applied to a shortened year.
  • 4 pages · 54 fields guided
  • Draws from your Estate File — Financial Accounts, Legal Instruments
Section 1

Before you start — the filing trap, and a death mid-year

Two things worth knowing before opening the form itself: how it has to be filed, and that a deceased person's residence isn't worked out the same way as a living one's.

It can't be e-filed through HMRC's free service

HMRC's own 2025–26 notes state it directly: do not submit the SA109 pages as an electronic attachment to an online filed tax return through HMRC's free Self Assessment service.

Filing it means commercial Self Assessment software, a professional agent, or paper — and paper filing means the earlier 31 October deadline, not 31 January.

The form's new name, for the same tax year the remittance basis ended

For 2025–26 the form is titled 'Residence and foreign income and gains (FIG) regime etc', not 'Residence, remittance basis etc' — because the remittance basis it used to be named for was abolished from 6 April 2025.

The GOV.UK web address still uses the old name; the form and its notes don't.

A death mid-tax-year needs separate guidance

If SA109 is being completed on behalf of someone who died during the 2025–26 tax year, HMRC's notes point to a different guidance path — RFIG20900 onwards — to establish that person's residence status.

This is not the standard Statutory Residence Test applied to a shortened year; treat it as its own question.

Two things worth knowing before opening the form itself: how it has to be filed, and that a deceased person's residence isn't worked out the same way as a living one's.

HM Revenue & Customs (HMRC) · SA109
Section 2

Residence status — boxes 1 to 14

The Statutory Residence Test mechanics: day-counting, split-year treatment, and the statutory 'ties'. Everything later in the form depends on how these boxes come out.

Not resident at all — box 1

Tick this if not UK resident for 2025–26. If ticked, most of the rest of this section — boxes 3 and 3.1 — doesn't apply, and the form moves straight to box 4.

Split-year treatment — boxes 3, 3.1 and 6

Box 3 claims split-year treatment for a tax year that was part non-resident, part UK-resident. Box 3.1 asks whether more than one of the eight statutory split-year 'Cases' applies — starting or ceasing full-time work overseas, being the partner of someone who did, or starting or ceasing a UK or overseas home are the Cases' broad shape.

Whichever Case (or Cases) applies has to be detailed in the free-text box 54, not just ticked here. Box 6 is the date the UK/overseas split begins or ends, only completed if box 3 is ticked.

The day-count — boxes 10, 11 and 11.1

Box 10 is the total number of UK midnight days for the year, including any 'deemed days'. Box 11 is how many of those are attributable to exceptional circumstances — illness, civil unrest, natural disaster or war are the notes' own examples — capped at 60 days a year. Box 11.1 is transit days spent in the UK, which are excluded from box 10 entirely, not folded into it.

These three categories are easy to mix up; the notes go out of their way to warn against double-counting or miscounting across them.

The other automatic tests and the statutory ties — boxes 7 to 9, 12 to 14

Box 7 asks whether the third automatic overseas test is met; box 8, whether there was a gap between overseas employments; box 9, whether an overseas home was used for 30 days or more.

Box 12 is how many of the five statutory UK 'ties' are held — family, accommodation, work, the 90-day tie, and the country tie — only completed in specific split-year scenarios. Boxes 13–14 cover days spent working more than three hours in the UK, and overseas.

The Statutory Residence Test mechanics: day-counting, split-year treatment, and the statutory 'ties'. Everything later in the form depends on how these boxes come out.

HM Revenue & Customs (HMRC) · SA109
Section 3

Personal allowances, and residence in other countries — boxes 15 to 24

Once residence status is settled, this section covers whether non-resident personal allowances apply, and relief where another country also has a claim on the same income.

Personal allowances as a non-resident — boxes 15 and 16

Box 15 claims entitlement to UK personal allowances as a non-resident under a Double Taxation Agreement — gated on nationality and residence in specific listed countries. Box 16 covers entitlement on some other basis, including as a 'dual resident remittance basis user' under certain agreements.

Country codes — boxes 17 to 19

A three-letter code for nationality and country of residence, using the full code table printed in the notes — each country flagged with a marker where the UK holds a Double Taxation Agreement with it. Box 19 covers 2024–25 residence too, only if also resident there that year.

Double Taxation Agreement relief — boxes 20 to 22

Box 20 is the amount of income claiming partial DTA relief. Box 21 claims relief because another country has residence-priority under the agreement — this needs Helpsheet 302 and its own claim form. Box 22 claims relief for other treaty provisions, needing Helpsheet 304 and its claim form.

Date of arrival, and the year before it — boxes 23 and 24

Box 23 is the date of arrival in the UK. Box 24 is the last UK-resident tax year before that arrival, entered as YYYY-YY.

Once residence status is settled, this section covers whether non-resident personal allowances apply, and relief where another country also has a claim on the same income.

HM Revenue & Customs (HMRC) · SA109
Section 4

Foreign income and gains — the FIG regime, and what's left of the remittance basis

This is the section that changed most for 2025–26. The current-year relief is the FIG regime; the remittance basis boxes that remain are for historic, pre-6-April-2025 amounts only.

The FIG regime — boxes 28 to 30

Box 28 claims relief on foreign income, box 29 on foreign gains — both available only to a 'qualifying new resident': someone UK resident in one of their first four years after at least ten consecutive non-UK-resident tax years.

Both require the underlying income or gains to also be reported on the relevant supplementary page — SA103F, SA104F, SA106 or SA108 — on a source-by-source basis, not as a single total. Box 30 covers UK income or gains treated as foreign under 'qualifying asset holding company' rules.

The remittance basis is gone for current income — boxes 37 to 39

From 6 April 2025 it's no longer possible to use the remittance basis of taxation, in the notes' own words. Boxes 37–39 exist only for legacy, pre-6-April-2025 amounts: box 37 for remitted nominated pre-2025 income or gains above the £10 de minimis, box 38 for Business Investment Relief claims (amount plus up to three Company Registration Numbers, more via box 54), box 39 for a previously-qualifying investment that has since stopped qualifying.

This is the section that changed most for 2025–26. The current-year relief is the FIG regime; the remittance basis boxes that remain are for historic, pre-6-April-2025 amounts only.

HM Revenue & Customs (HMRC) · SA109
Section 5

Two transitional reliefs — Overseas Workday Relief and the Temporary Repatriation Facility

Both are time-limited, both only apply in specific circumstances, and both need free-text detail at box 54 to support the claim.

Overseas Workday Relief — boxes 40 to 49

Box 40 makes the OWR election; box 41 makes the claim itself, which needs a prior election to exist. Box 43 flags the OWR transitional provisions — for someone who became UK resident and qualified for the pre-6-April-2025 OWR rules while electing the remittance basis in 2023–24 or 2024–25.

Boxes 44 and 46 are qualifying UK and foreign employment income after deductions. Box 47 is the maximum relief available — the lower of 30% of box 44 or £300,000. Box 48 is OWR actually claimed this year; box 49 is the total claimed across all years.

The Temporary Repatriation Facility — boxes 50 to 53

A transitional facility letting former remittance-basis users bring pre-6-April-2025 unremitted foreign income and gains into the UK at a flat rate — 12% for 2025–26, per HMRC's notes.

Box 50 makes the TRF election. Box 51 is the amount of personal TRF designations. Box 52 is the amount relating to capital payments or benefits received from trusts, matched to pre-6-April-2025 income or gains. Box 53 is how much of the box 51 designation was actually remitted this tax year.

Both are time-limited, both only apply in specific circumstances, and both need free-text detail at box 54 to support the claim.

HM Revenue & Customs (HMRC) · SA109
Section 6

Box 54, and after you file

A single free-text box carries the detail several earlier boxes rely on — HMRC names exactly which ones in the notes.

What box 54 has to cover

The notes explicitly list which numbered boxes need supplementary detail here rather than having their own space on the form: boxes 3, 3.1, 8, 11.1, 16, 37, 38, 39, 51, 52 and 53.

A tick alone on any of those — particularly the split-year Case at box 3.1 — is not treated as a complete answer without the explanation here.

Match the underlying pages

Anything claimed under the FIG regime, the remittance basis legacy boxes, or the reliefs above still has to be reported on its own supplementary page — SA103F, SA104F, SA106 or SA108 — for the actual income or gain concerned. SA109 claims the relief; it doesn't replace declaring the income itself.

Filing route decides the timetable

Since SA109 can't go through HMRC's free online service, confirm early whether commercial software, an agent, or a paper return is being used — that choice decides whether the working deadline is 31 January or the earlier 31 October.

A single free-text box carries the detail several earlier boxes rely on — HMRC names exactly which ones in the notes.

HM Revenue & Customs (HMRC) · SA109

Many people file SA109 themselves — that is what this walkthrough is for. If the situation behind it has stopped being simple — beyond what a careful person can safely do alone — Signum, Valoren’s own specialist desk, can take it on, and we say so plainly: it starts with a free intake, and if you do not need us, we will tell you. Prefer an independent adviser? STEP and the Chartered Institute of Taxation both keep public member directories, and neither pays Valoren a referral fee.

FAQ

SA109 questions, answered.

SA109 is the residence supplement to the main SA100 Self Assessment return. It's where someone declares a non-standard UK residence position — not resident at all, resident for only part of the year, or entitled to relief under rules that depend on residence and domicile history.
The remittance basis of taxation — what the form used to be named for — was abolished from 6 April 2025 and replaced by the FIG regime. The form was rewritten around the new rules and renamed to match; only the GOV.UK web address still carries the old title, kept for continuity.
No. HMRC's 2025–26 notes state directly that SA109 must not be submitted as an electronic attachment to an online filed return through their free service. Filing it means buying commercial Self Assessment software, using a professional agent, or filing on paper.
SA109 has no deadline of its own — as a supplement to SA100 it follows the same dates, 31 October after the tax year for a paper return and 31 January for an online one. Since HMRC's free service can't take SA109 at all, anyone filing on paper is working to the earlier date.
No — not for current-year income. From 6 April 2025 it's no longer possible to use the remittance basis of taxation. Boxes 37–39 on SA109 still exist, but only for pre-6-April-2025 amounts that hadn't yet been remitted; they're not a live election for this tax year.
The Foreign Income and Gains regime that replaced the remittance basis from 6 April 2025 — relief on foreign income and gains for a 'qualifying new resident': someone UK resident in one of their first four years after at least ten consecutive non-UK-resident tax years. It's claimed through boxes 28–30, alongside reporting the underlying income or gains on the relevant supplementary page.
A transitional, time-limited facility letting former remittance-basis users bring pre-6-April-2025 unremitted foreign income and gains into the UK at a flat rate — 12% for 2025–26, per HMRC's notes — rather than at normal Income Tax or Capital Gains Tax rates. It's claimed through boxes 50–53.
Not on its own. HMRC's 2025–26 notes direct anyone completing SA109 for someone who died during the tax year to separate guidance — RFIG20900 onwards — to work out that person's residence status, rather than applying the standard living-person Statutory Residence Test to a shortened year.

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Where this fits

SA109 is one form. The file behind it is the rest.

A deceased person's residence and domicile position — the same facts SA109 asks about — is also what IHT401 and the estate's Inheritance Tax account turn on, so the two filings should never be worked out from scratch twice.

The Legal Instruments record holds the domicile and residence history the claim rests on; the Financial Accounts record holds the foreign income, gains and remittance detail the boxes actually ask for.

HM Revenue & Customs (HMRC)54 fieldsFree to file — it's a supplement to SA100, not a separate submission45 minutes with Valoren
Attaches to the main return

This is a supplementary page. It's filed together with the main Self Assessment return, not on its own.

The main return — SA100
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