Moving from the UK to Georgia for the tax rate means clearing one hurdle first: the Statutory Residence Test, a set of statutory day counts and connection tests that decides whether you have actually stopped being UK tax resident, regardless of where you have registered a business. Get that wrong and Georgia's 1% is irrelevant, because HMRC still taxes your worldwide income. Get it right, come back too soon, and the temporary non-residence rules can pull certain income straight back into UK tax anyway. This guide works through what UK law actually requires, not just what Georgia offers.
What GBP 70,000 of freelance income actually costs, here and there
A UK sole trader earning GBP 70,000 in profit for 2026/27 pays income tax across three bands, roughly £15,432 in total, plus Class 4 National Insurance at 6% on profits between £12,570 and £50,270 and 2% above that, adding roughly £2,657. Class 2 is no longer compulsory above the small profits threshold; it is treated as paid at no cost, confirmed on gov.uk's self-employed National Insurance page. Add income tax and Class 4 together and the all-in bill comes to roughly £18,089, close to 26% of what was earned, funding NHS access that Georgia does not offer in its place.
| UK (2026/27, sole trader) | Georgia (IE + Small Business Status) | |
|---|---|---|
| Income tax | ~£15,432 | ~£700 (1% of turnover) |
| Class 4 National Insurance | ~£2,657 | None |
| Class 2 National Insurance | £0 (treated as paid) | None |
| Healthcare funded by the above | NHS access | Private insurance needed |
| Total, all-in | ~£18,089 (~26%) | ~£700 (~1%) |
That gap is real, and it is exactly why the Statutory Residence Test exists: it decides whether you actually get to stop paying the left-hand column, not whether Georgia will let you pay the right-hand one.
Does Georgia's 1% actually apply to you
The 1% applies to Georgian-source income, and for services that generally means work physically performed inside Georgia, not billed through a Georgian registration while you sit in Manchester or London. We cover this fully in Georgia's 1% tax and in the honest answer on paying it without living in Georgia. A UK national who registers a Georgian IE but keeps doing the actual work from a UK address has not moved anything for tax purposes, because the person is very likely still UK tax resident under the test below. Once that test is satisfied and the work genuinely happens in Georgia, the two questions line up rather than working against each other.
What the UK does when you leave
The Statutory Residence Test (SRT), set out in Schedule 45 to the Finance Act 2013 and explained in HMRC's guidance note RDR3, runs in three stages. The automatic overseas tests make you non-resident if you were UK resident in none of the previous 3 tax years and spend fewer than 46 days in the UK, or fewer than 16 days if resident in one of those years; a working-full-time-overseas route needs fewer than 91 UK days with no more than 30 spent working. The automatic UK tests make you resident at 183+ days, a UK home meeting specific availability conditions, or full-time UK work. Failing both, the sufficient ties test combines day bands with up to five ties, family, accommodation, work, 90-day, and country, and it is stricter than most summaries suggest: with prior UK residence, 91 to 120 days needs only 2 ties to make you resident, and over 120 days needs just 1.
The practical trap is the accommodation tie: a place to live in the UK available for at least 91 continuous days, with one night spent there, can be enough on its own to count. Combined with even a modest day count, a flat kept for family visits is the difference between resident and not. Separately, temporary non-residence catches people who come back too soon: if you were UK resident for at least 4 of the 7 years before leaving and your absence runs to fewer than 5 full tax years, HMRC taxes certain income, chiefly dividends from close companies, some chargeable gains and pension withdrawals, in the year you return, as though the years away never happened. Paying Georgia's 1% the whole time does not stop this.
Split-year treatment softens the departure or arrival year itself, dividing it into a UK part and an overseas part rather than taxing the whole year as resident, but it has no bearing on the 5-year temporary non-residence window. The UK keeps no published blacklist of low-tax destinations; the SRT and the temporary non-residence rules apply the same way regardless of country.
UK CFC rules, under Part 9A of TIOPA 2010, charge a UK-resident company on a foreign company's profits and do not apply to individuals at all, so a Georgian IE or LLC held directly by a person sits outside them entirely. The separate Transfer of Assets Abroad rules can attribute income back to a UK resident who transfers assets abroad and retains the power to enjoy it, but this targets people who have not genuinely left; once the SRT is cleared, it stops being the live risk. Structurally, an LLC run personally from inside the UK can raise a place-of-effective-management question for the company's own residence, a different risk from CFC attribution and one worth checking before choosing an LLC over an IE.
The UK and Georgia have had a double taxation convention in force since 11 October 2005, listed on gov.uk's tax treaties page, with the standard tie-breaker order of permanent home, then centre of vital interests, then habitual abode, then nationality. It resolves a genuine residency dispute, but has no bearing on the SRT itself and does not switch off temporary non-residence, both domestic law.
National Insurance stops once you are genuinely non-resident and no longer working in the UK, but so does your state pension record unless you act. Voluntary Class 2 contributions, £3.65 a week for 2026/27, are available to most people who worked in the UK immediately before leaving, applied for on form CF83 under gov.uk's guidance on paying voluntary National Insurance from abroad; Class 3, at £18.40 a week, is open more broadly but costs more. Georgia's Small Business Status carries no equivalent mandatory charge, and whether its funded pension scheme applies to you depends on residency and categorisation.
The steps, in order
- Work out which SRT test you actually meet before you leave, automatic overseas, automatic UK, or sufficient ties, since the answer decides whether anything else in this guide matters.
- Deal with any UK home deliberately. Selling it or letting it go removes the accommodation tie; keeping one available for 91+ days with a night spent there does not.
- Decide your return date before you leave, not after. Coming back inside 5 full tax years, having been resident for 4 of the previous 7, lets temporary non-residence tax specific income in the year you return.
- File split-year treatment through Self Assessment for your departure year, using the SA109 residence pages rather than the P85, which is built for PAYE leavers.
- Apply for voluntary Class 2 National Insurance on form CF83 if you want to keep your state pension record building while abroad.
- Register a Georgian IE and apply for Small Business Status, either in person or under power of attorney through remote company registration.
- Choose an IE over running an LLC personally from the UK if a place-of-effective-management question is a live concern.
- Keep records of your day counts and ties for every year the 5-year window stays open, since that is what HMRC asks for if you return early.
Timeline and cost
Registering a Georgian IE and getting Small Business Status is fast: a few days in person, or two to three weeks under power of attorney. The UK side takes longer to get right: working out which SRT test you meet, confirming split-year treatment for your departure year, and deciding whether the 5-year temporary non-residence clock genuinely suits your plans before committing to a return date. Budget weeks for that analysis.
The verdict for a UK national
Georgia is a strong fit for a UK national planning a genuine, multi-year move. The UK runs no exit tax, the treaty has been in force for two decades, and UK CFC rules do not reach an individually owned Georgian IE or LLC at all. What can undo it is honesty with the calendar: a UK home kept available "just in case" that quietly creates an accommodation tie, and planning to come back inside 5 full tax years, which lets temporary non-residence tax specific income as though the trip never happened.
For someone who clears the SRT cleanly and either stays away or plans to be gone longer than 5 years, the 1% holds up as legally as anything on this list. For someone testing the water for a year or two while keeping a London flat on standby, very little of the saving is actually secure yet.
We'll work through your Statutory Residence Test position, whether the 5-year temporary non-residence window applies to your specific plans, and which Georgian structure actually fits your situation, before you register anything here. Written summary included.
See what it costs
For the equivalent analysis for a German departure, see our guide on moving from Germany to Georgia, and for how Georgian-source income is actually defined, see Georgian-source income rules. A free consultation is the fastest way to find out where your own situation actually lands before you commit to either side of the move.
Key takeaways
- Work out which SRT test you meet before you leave, since the automatic tests and the sufficient ties test are decided by facts you control, day counts, ties and timing.
- Treat any UK home as a decision, not an afterthought. A flat kept "for visits" can create an accommodation tie on its own.
- Set your return date deliberately against the 5-year temporary non-residence window if you plan to come back at all.
- File split-year treatment through Self Assessment's SA109 pages, not the P85, if you already file a return.
- Apply for voluntary Class 2 National Insurance on form CF83 before your UK NI record lapses, since Class 3 costs more for the same protection.
- Choose an IE over personally running an LLC from inside the UK if you want to avoid a place-of-effective-management question.
Frequently asked questions
Does moving to Georgia automatically make me UK non-resident?
No. UK tax residency is decided by the Statutory Residence Test, which runs through automatic overseas tests, automatic UK tests, and then a sufficient ties test based on day counts and connections such as family, accommodation and work. Registering a Georgian business has no bearing on any of these tests.
What counts as an accommodation tie?
Having a place to live in the UK available to you for a continuous period of at least 91 days in the tax year, with at least one night actually spent there. A flat kept for family visits, even if rarely used, typically satisfies this and is the single most common tie people underestimate.
Does the UK have an exit tax like Germany or France?
No. The UK does not deem assets sold on departure. What it runs instead is the temporary non-residence regime, which taxes specific income and gains in the year you return if you come back within 5 full tax years of leaving, having been UK resident for at least 4 of the 7 years before departure.
What is temporary non-residence and how long does it last?
It treats certain income and gains realised while you were non-resident, chiefly dividends from close companies, some chargeable gains and certain pension withdrawals, as if they arose in the tax year you resume UK residence. It applies if your period of non-residence runs to fewer than 5 full tax years.
Do UK CFC rules apply to my Georgian company?
Not if you own it as an individual. UK CFC rules under Part 9A TIOPA 2010 charge a UK-resident company on the profits of a foreign company it controls, and they do not apply where a person holds the foreign structure directly. The Transfer of Assets Abroad rules are a separate, narrower question for individuals.
Is Georgia on a UK blacklist of low-tax countries?
No. The UK does not publish a list of low-tax destinations the way Spain does. The rules that actually govern a UK departure, the SRT and the temporary non-residence window, apply the same way regardless of which country you move to.
What happens to my National Insurance record when I leave?
Class 2 and Class 4 liability ends once you are genuinely non-resident and not working in the UK, but your state pension record stops building unless you act. Voluntary Class 2 contributions, cheaper than Class 3, are available to most people who were working immediately before they left.
Do I still need to fill in a P85 if I'm self-employed?
Usually not. The P85 is built for straightforward PAYE leavers claiming a tax refund. If you file a Self Assessment return for the year you leave, which most self-employed people do, you declare your residence position on the SA109 pages instead.
Is a Georgian IE or an LLC the better structure for a UK national?
Both sit outside the UK's company-only CFC charge when owned directly as an individual, so the choice usually turns on liability and turnover, and whether you plan to run the company personally from inside the UK, which can create a place-of-effective-management question for an LLC that an IE does not raise.