Hi. Long time viewer, first time poster.
A bit of a discussion around the office but something we've never been able to come to a comprehensive conclusion on despite much research...
For a long term non-resident individual returning to the UK, for the purposes of the split year provisions and apportionment of the day count limits, is there any sort of apportionment for days in the UK for someone with 0 or 1 tie. Obviously for 2 ties to the UK the 120 day limit is apportioned depending on the month of arrival.
Is the natural conclusion therefore that someone with 0 or 1 UK ties cannot fail the sufficient ties part of the split year tests (assuming every other relevant condition of the SRT up to this point had been met) or do you use the same apportioned day limits as for 2 ties? Alternatively is the upper limit just 183 days?
Would appreciate any guidance on this. I've been through legislation and searched for internet articles and certainly have a view but not one I feel 100% confident in.
Thanks in advance