The LSR Partners team breaks down one of the most misunderstood parts of the SRT: how Deemed Days work, when they count toward your UK day total, and when they don’t.
If you’re in the UK at midnight, that day counts as one full UK day for SRT purposes.
A qualifying day is not a full day unless the deeming rule applies. Typical examples:
Example: Arrive Monday, stay overnight, leave Tuesday.
The deeming rule switches on only if all three are true:
Once the rule applies, every qualifying day after the first 30 becomes a full UK day for SRT counting. That can move you above an SRT threshold and into UK tax residency.
If HMRC conclude you’re UK resident, you may be taxed on worldwide income (subject to other reliefs). Even if you’ve carefully counted midnights, qualifying days can push you over the line if you’ve got enough UK ties and more than 30 qualifying days.
An executive transits through London multiple times, often departing late evening. After a prior UK-resident year and with 3 UK ties in place, they pass 30 qualifying days by autumn. Each subsequent same-day transit is deemed a full day, tipping them over the SRT day threshold. Early modelling could have moved two trips or re-timed departures to stay non-resident.
You get clear residency modelling, day-count reviews, and travel-planning rules of thumb, so you pay the right tax in the right place at the right time and avoid HMRC surprises. You’ll get clarity and confidence.
Do qualifying days always count as full days?
No. Only after the first 30 qualifying days and if the other two conditions apply (recent UK residence and 3+ UK ties).
If I’m never in the UK at midnight, can I still be UK-resident?
Yes, if the deeming rule applies and enough qualifying days convert to full days for SRT totals.
What are UK ties?
SRT looks at ties such as family, accommodation, work, 90-day tie, and country tie (depending on your leaver/arriver status). The more ties you have, the fewer days you can spend before becoming resident.
Can LSR track days for me?
Yes. LSR can review your historic data, set up ongoing tracking, and model forward travel so you stay within your chosen residency outcome.
Contact LSR Partners today to speak with our expert team and pay the right tax, in the right place, at the right time.
