COVID-19 EXPERT LEGAL INSIGHTS

Welcome relief for COVID-19 workers

15 April 2020

The Chancellor, Rishi Sunak, has written to the chair of the Treasury Select Committee to confirm temporary changes to the Statutory Residence Test (SRT). The SRT determines whether a person is within scope of UK income and capital gains tax, with the number of days physically spent in the UK being a major factor.
 

The government will amend the SRT to ensure any days spent in the UK between 1 March and 1 June 2020 by individuals “working on COVID-19 related activities will not count towards the residence tests.”

The aim is to support those coming to the UK in this period with a defined skill set to serve the national cause, while at the same time ensuring their global earnings are not in scope of UK taxation. Anaesthetists and engineers working on ventilator design and production receive particular mention for the work in mind. The full criteria of the required skill set for this work and the finer detail of whether UK tax will still be due on paid work done in the UK even if the days spent do not count for other purposes more generally within the SRT will be confirmed within the forthcoming Finance Bill to take effect from 1 March 2020.  

About the author

Julie Jaggin is a Senior Associate in the Private Client teamJulie has extensive experience of advising both UK-based and international clients on a wide range of private client work, including pre-UK immigration tax-planning, lifetime gifting from UK and offshore structures, the creation and administration of UK and offshore trusts, Wills, family constitutions, probate, corporate tax-planning vehicles, lasting powers of attorney and deputyships. 

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