UK Tax Residence: When the Details Behind Your Travel Matter

The UK statutory residence test (‘SRT’) is often viewed as a simple exercise in counting days. In practice, however, the circumstances behind those days can be just as important as the numbers themselves.

In the case of Parker v HMRC [2026], Mr Parker had spent 100 days in the UK during the 2019/20 tax year. After seven days were accepted as capable of being disregarded due to Covid-19 restrictions, four further days became critical. Excluding them reduced his total to 89 days, below the 90-day threshold relevant to his particular circumstances.

Three of the disputed days related to transit through the UK. HMRC argued that the transit rules could not apply because Mr Parker had booked separate tickets. The tribunal took a more practical approach, finding that the nature and continuity of the journey were more important than whether the travel was booked on a single ticket.

The fourth day arose after Mr Parker's onward flight to Dublin was cancelled due to severe weather. Having already boarded the flight, he was required to stay overnight near Heathrow and travel the following morning. The tribunal accepted that this was outside his control and that the additional day could be disregarded as an exceptional circumstance.

The decision is a useful reminder that SRT disputes are not simply about counting days, rather the facts behind the day count, and the evidence supporting them, also matter.

Boarding passes, booking confirmations, cancellation notices, hotel records and notes can all help establish what actually happened. This can be particularly important where an unexpected event occurs several years before an HMRC enquiry.

However, the Parker case should not be taken to mean that every cancelled flight or separate ticket will result in a day being disregarded, rather the outcome will always depend on the particular facts and the evidence available.

For advisers and internationally mobile clients, the practical takeaway is simple: don't just track UK days, rather keep a record of the story behind them. When a client is close to an SRT threshold, good record-keeping can make the difference between having an explanation and being able to prove it.

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How can Sanctuary help?

For internationally mobile individuals, UK tax residence is often determined by more than simply counting days. As the Parker v HMRC case demonstrates, the circumstances behind those days and the quality of supporting evidence can be just as important.‍

At Sanctuary, we help clients monitor their UK day counts, assess residence risks under the Statutory Residence Test, and maintain appropriate records to support their position if challenged by HMRC. Whether you are relocating, travelling frequently, or managing cross-border business interests, early planning and good record-keeping can help avoid unexpected UK tax exposure. Contact us via our website or email hello@sanctuary.ae for a bespoke consultation.

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Visit our Tax & Advisory service page to find more about our tax & residency advisory services, or contact us for a bespoke consultation via the contact form or email us at: hello@sanctuary.ae.