Tax Tips for Canadians coming to the UK or Returning to Canada
Important information: Canadians in London provides general information and introductions only. We do not provide tax, legal, financial or investment advice. Cross-border tax rules are complex and depend on your personal circumstances. You should seek advice from a qualified tax professional before making decisions. We may receive a referral fee, sponsorship fee or other commercial benefit from selected partners featured on this page.
For Canadians Living in or Relocating to the UK
Understand your tax residency status
Your tax position will usually depend first on where you are tax resident. When you move to the UK, you may become UK tax resident depending on the number of days you spend in the country and your personal ties.
The UK uses the Statutory Residence Test to determine tax residency. Canada will also consider whether you have become non-resident for Canadian tax purposes or remain a factual resident of Canada.
Tell CRA when you leave Canada
If you leave Canada to live in the UK, you may need to update the Canada Revenue Agency, file a departure return, report your date of departure, and understand whether Canadian non-resident rules apply after the move.
Even after leaving Canada, some Canadian-source income may still be taxable in Canada or subject to non-resident withholding tax.
Declare worldwide income in the UK
If you become UK tax resident, you may need to report worldwide income to HMRC. This can include Canadian pensions, investment income, rental income, employment income, dividends and other Canadian-source income.
The Canada-UK tax treaty may help reduce double taxation, but income still needs to be reported correctly in the right country.
Review pensions, CPP, OAS, RRSPs and RRIFs
Canadian pensions and registered plans can have different tax treatment once you are UK resident. CPP, OAS, workplace pensions, RRSP withdrawals and RRIF income may be taxable depending on the type of income, your residency status and the treaty position.
Do not assume that the Canadian treatment will automatically be the same in the UK.
Check TFSAs, ISAs and investment accounts
A TFSA may be tax-free in Canada, but that does not automatically mean it is tax-free in the UK. Likewise, ISAs are UK tax-efficient accounts, but they may not receive the same treatment in Canada if you later return.
Canadian investment accounts, dividends, interest and capital gains should be reviewed carefully when moving between the two countries.
Canadian dividends and non-resident withholding tax
Canadians living in the UK who still hold Canadian investments may receive dividends from Canadian companies. These payments are generally subject to Canadian non-resident withholding tax.
The standard Canadian non-resident withholding rate is 25%, but the Canada-UK tax treaty may reduce the rate on eligible Canadian dividends, often to 15% for individuals. The dividend income and tax withheld are usually reported on an NR4 slip issued by the payer or financial institution.
The reduced treaty rate is not always automatic. Canadian payers, brokerages and financial institutions may ask for evidence that the recipient is tax resident in the UK and eligible for treaty relief. If they do not have sufficient documentation, they may apply the full 25% withholding rate.
Keep your NR4 slips, brokerage statements, UK tax records and evidence of foreign tax paid.
Canadian property, rental income and selling while abroad
If you live in the UK but still own property in Canada, especially a rental property, there may be tax obligations in both countries.
Canadian non-residents who receive rental income from Canadian property may be subject to non-resident withholding tax. In some cases, withholding is calculated on gross rental income unless the correct elections and filings are made. Some property owners may be able to file an NR6 election so withholding is based on estimated net rental income instead, but this must be handled properly and usually involves a Canadian agent.
You may also need to file a Canadian Section 216 return to report the rental income and claim eligible expenses. At the same time, if you are UK tax resident, you may also need to report Canadian rental income to HMRC as part of your worldwide income. Foreign tax credits may help reduce double taxation, but the reporting still needs to be done correctly.
Selling Canadian property while living abroad can also create additional compliance steps. Non-residents selling certain Canadian property may need to notify CRA and apply for a Certificate of Compliance before or shortly after the sale. In some cases, funds may be withheld during the transaction until the relevant Canadian tax position is dealt with.
Foreign income and gains rules
The UK’s previous remittance basis rules for non-domiciled residents have changed. From 6 April 2025, the remittance basis was replaced by a residence-based foreign income and gains regime.
This is a specialist area, particularly for new arrivals with Canadian income, investments or gains. Speak to a qualified cross-border adviser before assuming foreign income can be left outside the UK tax net.
National Insurance and CPP
If you work in the UK, you may need to pay National Insurance Contributions. Canada and the UK have a social security agreement that may help coordinate certain contribution periods and pension eligibility.
Keep records of CPP and National Insurance contributions, especially if you have worked in both countries.
What if You Also Have US or European Tax Connections?
Not every Canadian in the UK has a simple Canada-UK tax picture. Some people also have US citizenship, a US green card, US investments, European property, EU employment income, or previous residency in another country.
This can make the tax position more complex. US citizens and resident aliens are generally required to report worldwide income to the IRS even when living abroad, which means a Canadian in the UK with US status may have filing obligations in the US as well as the UK and Canada.
European tax rules can also vary significantly by country. There are no single EU-wide rules that decide how every EU country taxes individuals, but the country where you are tax resident can usually tax worldwide income, including pensions, property income, investment income and capital gains.
For Canadians with links to the US, Europe or multiple countries, cross-border advice becomes especially important. This may apply if you have:
-
US citizenship, a green card or US tax filing history
-
US investment accounts, pensions or employment income
-
property, pensions or investment accounts in an EU country
-
employment income from more than one country
-
a spouse or family member with a different tax residency or citizenship position
-
plans to move again after leaving the UK
-
In these cases, the question is not just “Canada or the UK?” It may involve several countries, treaty rules, foreign tax credits, reporting obligations and timing decisions. Speak to a qualified cross-border tax adviser before making major moves, selling assets, drawing pensions or changing residency.
For Canadians Returning to Canada from the UK
Tax residency on return
When you return to Canada, you will generally become Canadian tax resident again and may need to report worldwide income from the date your Canadian residency resumes. You should inform CRA of your change in residency and update your address.
UK pensions - visit our pension guide
UK pensions, including workplace pensions, may need to be reported in Canada as foreign income. The Canada-UK tax treaty may help reduce double taxation, but the treatment will depend on the type of pension and how it is paid.
Visit our pensions section for more information.
Selling UK property
If you sell UK property before or after returning to Canada, you may need to consider UK capital gains tax.
You may also need to consider Canadian reporting if the property is sold after you have re-established Canadian tax residency.
UK bank accounts, ISAs and investments
Any remaining UK bank accounts, ISAs, pensions or investment accounts may need to be considered as part of your Canadian tax position once you return.
The Canadian treatment of UK tax-efficient accounts may differ from the UK treatment, so do not assume an ISA will be treated in Canada the same way it was treated in the UK.
Timing income and withdrawals
Before leaving the UK, it may be worth reviewing the timing of income, pension withdrawals, investment gains, bonuses and use of UK tax allowances.
Once you leave the UK, some allowances or planning options may no longer be available in the same way.
Social security coordination
Canada and the UK have a social security agreement that may help coordinate certain contribution periods, such as National Insurance and CPP, for state pension eligibility.
Keep clear records of contributions in both countries.
10-Point Expat Tax Checklist
Use this as a quick summary of the main areas to review when moving between Canada and the UK.
1. Know your tax residency status
Work out whether you are tax resident in the UK, Canada, or potentially exposed to reporting in both countries. Residency is the starting point for most cross-border tax questions.
2. Update CRA when you leave or return
Tell CRA when your residency changes. This may involve updating your address, reporting a departure or return date, and filing the correct Canadian tax return for the year of the move.
3. Report worldwide income where required
UK tax residents may need to report foreign income to HMRC. Canadian tax residents may need to report worldwide income to CRA. Do not assume income is ignored simply because it was earned in the other country.
4. Check Canada-UK treaty relief
The Canada-UK tax treaty may help reduce double taxation, but treaty relief is not the same as ignoring income. The income usually still needs to be reported correctly.
5. Review pensions and registered plans
Check how CPP, OAS, UK pensions, RRSPs, RRIFs and workplace pensions are taxed before drawing income or moving funds.
6. Check TFSAs, ISAs and investment accounts
Tax-free accounts in one country may not be tax-free in the other. Review TFSAs, ISAs, dividends, interest, capital gains and investment accounts before and after moving.
7. Handle rental income properly
If you own rental property in Canada or the UK, check whether the income must be reported in both countries and whether withholding tax, foreign tax credits or special filings apply.
8. Plan before selling property
Selling property while abroad can create extra tax and compliance steps. This may include capital gains tax, CRA notification, certificates of compliance or withholding during a sale.
9. Keep cross-border records
Keep tax returns, payslips, P60s, P45s, CRA notices, NR4 slips, pension statements, rental records, mortgage interest records, exchange-rate records and proof of tax paid.
10. Get advice before major decisions
Speak to a cross-border tax adviser before renting out property, selling property, drawing pensions, moving large sums, changing residency or returning to Canada.
Our Tax Specialists
At Maple Oak Accountancy, we offer accountancy and tax services for individuals, landlords and small companies. Specialising in cross-border UK & Canadian tax strategies
Certified Cross-Border Accountant CAN UK
Wayne Bewick is an experienced Canadian Chartered Professional Accountant, Certified Financial Planner, and a U.S. Certified Public Accountant, Wayne leads the Private Client Division at Trowbridge and thrives on problem-solving and making complex tax matters less daunting for his international clients.
Certified Cross-Border Accountant US UK CAN