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Day (or rather midnight) Calais trips re 90 days

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Seems good, sensible planning re SRT. See paras 121, 151, 192, 214 & 215.

Also, para 152 is wrong re TNR. It's 6 complete tax years, not 5 to avoid TNR. Employment income (para 153) is outside its scope and that planning appears to have worked per para 89.

https://caselaw.nationalarchives.gov.uk/ukftt/tc/2022/199

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