Exceptional circumstances may mean that individuals can disregard days spent in the U.K. during the crisis period when determining their tax residency, according to a representative for HM Revenue & Customs who spoke on condition of anonymity.
The rules for nondomiciled taxpayers, or non-doms, state that U.K. residents with permanent homes outside the U.K. may not have to pay U.K. tax on foreign income if they spend a majority of their time outside the country. While the rules are intended to allow for secondments or other legitimate business needs, the term non-dom is often used to refer to wealthy individuals in the U.K. and is closely tied to the idea of a deliberate tax avoidance strategy.
The HMRC spokesman said easing of the residency requirements will depend on individual cases. It should be read together with existing guidance, and it "does not represent a change in the rules or requirements for determining tax residency," he said.
"This is not a blanket ruling," he said.
In the tax year 2018-2019, there were 223,000 nonresident taxpayers. More than 2,600 of those claimed at least one day in the U.K. as being because of exceptional circumstances, according to HMRC.
The U.K. applied restrictions to people's movements on Monday night, ordering nonessential businesses to close and people to remain in their homes and avoid travel unless absolutely necessary. Many countries including Austria and Belgium have closed their borders, and commercial flights are running far below the normal level to help stem the spread of the disease.
"We have previously applied the same rules in the same way when looking at individuals personally affected by the 2014 Ebola outbreak in West Africa," the HMRC spokesman said.
"We are keeping the situation under review," he added.
--Editing by John Oudens.
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