RFIG22470 | Statutory Residence Test (SRT):International tax clarifications due to coronavirus (COVID:19):International tax clarifications due to coronavirus (COVID 19) - Deemed days

If an individual is not in the UK at midnight that day does not count as a day spent in the UK. This is subject to the deeming rule.

The deeming rule applies if:

• the individual has at least 3 UK ties in the tax year

• the number of days the individual was in the UK but not at midnight was more than 30

• the individual was UK resident in 1 of the 3 tax yeas preceding the relevant tax year

If the individual meets these conditions, then any days above 30 would count as a day of presence in the UK for the SRT (see RFIG20720).

The modifications apply if:

• the days falls in the period beginning with 1 March 2020 and ends with 1 June 2020

• on that day the individual is in the UK carrying out specified coronavirus disease related work, and

• the individual is resident in another country for tax purposes

If all the conditions are met, those days will not count towards the 30 day threshold for deeming rule purposes.