A system designed to count days rather than passports
The European Union’s new Entry/Exit System (EES) quietly changes how border officials record visits by non‑EU nationals, highlighting the need for clear UK holiday home tax advice for property owners.
Since 12 October 2025, the system has replaced manual passport stamping with a digital record of your arrival and departure. When a UK passport holder enters the Schengen area, biometric data – fingerprints and a photograph – are captured and stored for three years. The rationale is better security and to stop visitors overstaying. For holiday home owners who used to cross borders with few questions asked, the new system means the authorities will know exactly how long they have been in the EU.
EES applies only to Schengen members – a group of 27 continental countries – and does not include the Republic of Ireland or Cyprus. Registration is automatic at the border, costs nothing and takes place on arrival. However, the process can lengthen queues, as travellers must submit fingerprints and have their photograph taken. After completion, the digital record replaces passport stamps and is used each time you enter or exit the Schengen area.
Why counting days matters for UK holiday home tax advice
EES is a border security tool, but it also makes it easier for tax authorities to police residency rules. Under the Schengen “90‑days in any 180‑day period” rule, UK visitors cannot spend more than three months in the bloc without obtaining a visa. The digital record provides an irrefutable log of days spent in each country and can be cross‑referenced with local tax systems.
For example, Spain, France and Portugal treat anyone who spends more than half of the year in their territory as a tax resident. Previously, holiday home owners could argue about precise arrival dates when challenged; now, the system holds that information centrally.
For UK tax purposes, the statutory residence test is equally sensitive to day‑counting. HM Revenue & Customs (HMRC) says you are normally UK resident if you spend 183 or more days in the UK during the tax year, or if your only home was in the UK for 91 days or more and you stayed there at least 30 days.
Conversely, you are usually a non-resident if you spend fewer than 16 days in the UK or if you work abroad full-time and spend fewer than 91 days in the UK. Residency determines whether you pay UK tax on your worldwide income or just on your UK income. EES data will make it harder to argue residency status if your personal records do not align with your digital travel history, emphasising the importance of UK holiday home tax advice.
Overseas property income is treated separately
UK residents must pay income tax on foreign rental income. HMRC’s property income manual explains that rent and other receipts from properties outside the UK are taxed as the profits of an overseas property business. Profits or losses are calculated like those of a UK property business, but they are taxed separately: losses from one cannot be set against the other.
The profits are chargeable to income tax only if the business is carried on by a UK resident. Before April 2025 some non‑domiciled individuals could elect to be taxed only on income remitted to the UK, but the Foreign Income and Gains (FIG) regime now generally subjects all UK residents to tax on their worldwide income.
HMRC guidance also notes that while most foreign income is taxed like UK income, there are special rules for pensions, certain employment and rent from property. If you have multiple overseas properties, you can offset losses between them but not against UK properties.
All foreign rental income must be reported in the foreign section of your Self Assessment tax return, following UK property tax guidance for overseas homes. If you owe tax, you must register for Self Assessment by 5 October following the end of the tax year. The return must include income already taxed abroad if you plan to claim foreign tax credit relief.
Risks for holiday home owners
Holiday home owners in Spain, Portugal or France often spend months at a time enjoying the sun or refurbishing their property. With EES registering each entry and exit, EU authorities can easily check when a visitor has surpassed the 90‑day limit. Some governments are expected to use this data to identify individuals who may be inadvertently meeting their domestic residency thresholds. If you stay in a country for more than 183 days, you may owe income tax there on your worldwide income. EES will also highlight repeated stays that may signal an undeclared holiday letting business.
From a UK perspective, lengthy stays abroad can complicate your residence status. Spending long periods in Spain or France reduces your days in the UK and could result in your becoming non‑resident, which would normally mean you pay UK tax only on your UK income. But even if you become a non‑resident, your overseas property profits may still be taxed in the country where the property is located. Meanwhile, UK‑resident owners must continue to pay UK tax on those profits. Coordinating tax obligations across two jurisdictions becomes more complex, and mistakes can trigger penalties or interest.
Another risk is failing to report the rental income of a foreign holiday home, which is why UK property tax guidance for overseas homes is essential. HMRC’s guidance makes clear that you must include foreign rental income on your tax return and cannot offset losses against your UK property business. The digital record created by EES, combined with data‑sharing agreements across Europe, makes it easier for tax authorities to match property ownership with travel patterns and identify unreported income. Those who have relied on the low visibility of short‑term lets may find themselves subject to scrutiny.
Practical steps and tax planning for holiday home owners
To reduce the risk of investigation, holiday home owners should do the following:
- Track time spent in the EU – Keep a personal log of entries and exits that matches the EES record, which supports tax planning for holiday home owners. Plan trips to stay within the 90‑day‑in‑180‑day limit and ensure you do not inadvertently create tax residence in the country where your property is located.
- Review your UK residency status – Use the statutory residence test as guidance. Remember that 183 days in the UK usually makes you resident, while fewer than 16 days normally means you are non‑resident.
- Declare all foreign rental income – Register for Self Assessment if you have any foreign income. Use the foreign section of your tax return to report rents, even if tax was deducted overseas.
- Keep separate accounts for overseas properties – because overseas property profits cannot be netted against UK property profits, you should maintain clear records of income, expenses and any tax paid abroad.
- Monitor upcoming changes – The EU’s travel authorisation system (ETIAS) is expected to start in late 2026. Check the official guidance and ensure you obtain authorisation when required.
How Apex Accountants can help
Holiday home ownership brings lifestyle rewards and tax complexities. Apex Accountants & Tax Advisors combine expertise in UK tax law with an understanding of EU residency rules. We help clients evaluate how EES data may affect their tax residency, plan their time abroad to stay within the 90‑day rule, and organise their affairs to avoid dual‑taxation pitfalls. Our advisory services include:
- Residence status reviews – We analyse your travel patterns and family ties to determine your UK tax residence and advise you on the implications.
- Foreign income reporting – Our team prepares Self Assessment returns, ensuring that we correctly report overseas rental income and claim foreign tax credits where available.
- Cross‑border tax planning – We work with partner firms in the EU to coordinate tax obligations, so you comply with both UK and local laws and avoid penalties.
Whether you are purchasing a holiday home, already own one, or plan to spend more time abroad in retirement, Apex Accountants can provide tailored advice to help you stay compliant with changing border and tax rules. Contact us today to discuss your circumstances and plan with confidence.
Frequently asked questions
What is the EU Entry/Exit System, and when did it start?
The EU’s Entry/Exit System is a digital border record. From 12 October 2025, UK passport holders are required to provide fingerprints and a photograph at their first entry into the Schengen area. The system replaces passport stamps and stores your travel data for three years.
How long can UK citizens stay in the Schengen area without a visa?
You can stay for up to 90 days in any 180‑day period. The EES makes it easier to enforce this rule, and there is a penalty approach for exceeding it.
Do UK residents pay tax on income from overseas holiday homes?
Yes. If you are a UK resident, you normally pay UK income tax on foreign rental income. The profits from an overseas property business are calculated like a UK property business but taxed separately.
How do I know if I’m a UK resident for tax?
HMRC uses a statutory residence test based on the number of days you spend in the UK. Spending 183 days or more in the UK usually makes you resident, while fewer than 16 days usually makes you non‑resident. Other factors, such as having your only home in the UK or working full time here, can also make you resident.
What steps should I take if I rent my holiday home?
You must register for self-assessment and report your overseas rental income in the foreign section of your tax return. Keep detailed records of rents and expenses and seek advice on claiming any foreign tax credits.
Will the EES information be shared with HMRC?
The EES is operated by the EU for immigration control. While there is no public statement that data will be directly shared with HMRC, tax authorities across Europe are increasingly using digital records to enforce residency rules. Holiday home owners should therefore assume that HMRC may use their travel data to verify tax status.
