Russian has been in the UK over the last 3 years. They have an investment in the UK from which they are paid interest - there is no other income. The days spent in Russia in each of these years is less than 60 and the remainder has been spent in the UK.
Presumably they will be considered tax resident in the UK as they spent less than 183 days in Russia.
Can anyone confirm?
Thanks
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365 - 60 is not hard
They will be considered resident in the UK, because they spent more than 183 days in the UK. That is the first test that has always been there.
They might then be considered resident in Russia, I do not know, and then you would need to consider the tiebreaker in the treaty.
You think maybe they have copied our rules?
My Ernst & Young 2013/14 World Personal Tax Guide says:
"For tax purposes, individuals are considered resident if they are present in the country for 183 days of more in a period of 12 consecutive months. At the time of writing, the Ministry of Finance and the Federal Tax Service were promulgating a view that an individual must also spend at least 183 days in the Russian Federation in a calendar year to be considered tax resident. However, this further requirement is not stated in the Tax Code."