The outbreak of the virus is in fact impacting people’s ability to travel and move freely to and from the UK or, is requiring individuals to remain longer in the UK, regardless of previously agreed plans and business commitments.
In this instance, HMRC have clarified in their Residence, Domicile and Remittance Basis Manual that where individuals are in the UK longer than expected because of travel restrictions imposed as a result of COVID-19, then these additional days in the UK can be disregarded due to exceptional circumstances.
Circumstances can be considered exceptional when an individual:
- is quarantined or advised by a health professional or public health guidance to self-isolate in the UK as a result of the virus
- finds himself/herself advised by official Government advice not to travel from the UK as a result of the virus
- is unable to leave the UK as a result of the closure of international borders, or
- is asked by his/her employer to return to the UK temporarily as a result of the virus
This advice affects all internationally mobile employees, hence anyone who is a traveller and who may be in or out of the UK more than anticipated due to the restriction on travel movements.
This guidance is important at this stage as days of presence in the UK can affect whether an individual either becomes or remains a UK tax resident.