SA109 residence pages: the UK day-count boxes and the records behind them

What is the SA109, and when is it due?

The SA109 is the “Residence and foreign income and gains (FIG) regime etc” supplementary pages. They go with the SA100, the main tax return.[3]

For the 2025–26 tax year (6 April 2025 to 5 April 2026), GOV.UK gives these deadlines:[4]

• Paper return: HMRC must receive it by 11:59pm on 31 October 2026.
• Online return: you must submit it by 11:59pm on 31 January 2027.

To file these pages online, HMRC’s notes say you’ll need to either:[1]

• buy software from a commercial supplier, or
• authorise a professional agent to file for you.

Don’t send the pages as an electronic attachment to an online return.[1]

The form itself is short. The work is knowing your numbers. This guide doesn’t tell you what to claim.

Educational, not tax advice.

Who needs to fill in the SA109?

HMRC’s notes say to fill in these pages if:[1]

• you’re not resident in the UK, or
• you’re resident and you:
  • became UK resident during the year
  • are due split year treatment (your tax year is split into a UK part and an overseas part)
  • want to make certain claims or elections: the FIG regime, Overseas Workday Relief, the temporary repatriation facility, or Business Investment Relief

The residence status boxes come first. Box 1 is for “not resident in the UK for 2025–26”. Box 3 is for split year treatment.[1]

If you put ‘X’ in box 1, the notes say:[1]

• go to box 4
• boxes 3 and 3.1 don’t apply
• you must also put an entry in boxes 7 to 13 where applicable

If you put ‘X’ in box 3, the notes say:[1]

• give details of which split year case applies in box 54 (“Any other information”)
• fill in box 6, the date the UK part of the year begins or ends

Which applies to you is a residence question, and this guide doesn’t answer it. For the statutory residence test (SRT), HMRC’s test for UK residence, start with Am I a UK tax resident? For split years, see when your situation changes mid-year.

What does each day-count box ask for?

In short, then box by box.[1][2]

Box 10: number of days spent in the UK

Fill in box 10 only if you put ‘X’ in box 1 or box 3. The notes build the number like this:[1]

1. Count midnights, not arrival dates. Count the days in the tax year when you were in the UK at midnight. HMRC’s manual says you spend a day in the UK if you’re here at the end of the day.[5]
2. Add deemed days, if the deeming rule applies. Add any days over 30 that count as deemed days. Note in box 54 how many are included.
3. Keep exceptional days in. You must include midnights spent in the UK due to exceptional circumstances. They are also shown in box 11.
4. Leave transit days out. They go in box 11.1 instead.
5. Split year? With ‘X’ in box 3, show only UK days in the overseas part of the year.
6. No UK days? Put a zero.

What is the deeming rule? The notes say it applies only if all three are true:[1]

• you were UK resident in one or more of the previous 3 tax years
• you have at least 3 UK ties for the tax year
• you were in the UK on more than 30 days in the tax year when you weren’t here at midnight

It won’t apply if you’ve put ‘X’ in box 7 (the third automatic overseas test).[1]

HMRC’s manual calls a UK day without a midnight a “qualifying day”. Once all the conditions are met, every qualifying day after the first 30 is treated as a day spent in the UK.[6]

The day count isn’t the whole picture. The 183-day myth sets out the order HMRC applies the tests in.

Box 11: days in box 10 attributed to exceptional circumstances

Box 11 asks for the days you spent in the UK due to exceptional circumstances beyond your control. HMRC’s examples are:[1]

• an illness that happened while you were in the UK and stopped you travelling
• national and local disasters, such as civil unrest, natural disasters and the outbreak of war

The most that can be attributed to exceptional circumstances is 60 days in any tax year. So box 11 should not exceed 60.[1]

HMRC’s manual says whether circumstances count as exceptional will always depend on the particular facts, your circumstances and the choices available to you.[8]

It also says some parts of the SRT may take these days into account and some may not. RFIG22220 and RFIG22230 have the detail.[5] If you’re relying on these days, raise it with your adviser.

Box 11.1: midnights in the UK while you were in transit

The notes say a transit day is one where all of these are true:[1]

• you’re travelling from one country outside the UK to another country outside the UK
• on the way, you arrive in the UK as a passenger and leave the next day
• between arriving and leaving, you don’t take part in activities unrelated to your passage through the UK

Put the total in box 11.1. Don’t include these days in any entry in box 10.[1]

HMRC’s manual adds detail:[7]

• It describes the journey as being on a through ticket.
• The test is activities “to a substantial extent unrelated” to your passage.
• Related: dinner or breakfast at your hotel.
• Unrelated: a film at a local cinema, time in your UK home, or catching up with friends or relations.
• The day you leave the UK may still be a qualifying day under the deeming rule.

Box 12: how many ties to the UK you had

The notes cover two cases:[1]

• Split year case 4 or case 8 (‘X’ in box 3, not box 1): put the number of UK ties you had in the overseas part of the year.
• Neither box 1 nor box 3 filled in: you don’t need to fill in box 12.

HMRC doesn’t say in the box 12 notes what to enter if you’ve put ‘X’ in box 1. The box 1 note says you must also put an entry in boxes 7 to 13 where applicable.[1]

The five UK ties, in brief, following HMRC’s notes:[1]

• Family tie. Your husband, wife, civil partner (unless separated) or partner you live with as husband or wife is UK resident for the year. A child under 18 resident in the UK can also give a family tie, but special rules apply.
• Accommodation tie. A place to live in the UK, available to you for a continuous 91 days, where you spend at least one night in the tax year. At a close relative’s home, it’s 16 nights. See “Available accommodation”, decoded.
• Work tie. At least 40 days of work in the UK in the tax year. A day counts only if you work more than 3 hours. See UK work days.
• 90-day tie. More than 90 days in the UK (at midnight) in either of the two previous tax years: for 2025–26, that’s 2023–24 or 2024–25.
• Country tie. You only need to consider it if you were UK resident in one or more of 2022–23, 2023–24 and 2024–25. HMRC words the test two ways (below).

The country tie, two wordings. The SA109 notes say: “You have a country tie if you spend the majority of your midnights in the UK in the 2025 to 2026 tax year.”[1]

HMRC’s manual (RFIG20580) says you have a country tie if the UK is “the country in which they were present at midnight for the greatest number of days in that tax year”. It adds that a shared top count that includes the UK also gives a country tie.[9]

HMRC doesn’t say why the two are worded differently. In a year spread across several countries, they can read differently. Our country tie guide follows the manual. If the difference matters for your year, take it to your adviser.

Box 13: days you worked for more than 3 hours in the UK

The notes describe two situations:[1]

• Third automatic overseas test (‘X’ in box 1 and box 7): put the total days in the tax year you worked for more than 3 hours in the UK.
• Split year case 1 or case 6 (‘X’ in box 3, not box 1): put the total of those days in the overseas part of the year.

For what counts as work, the notes point to RFIG20740. Work takes its everyday meaning:[10]

• for an employee, the activities carried out in the performance of their duties
• for the self-employed, the activities carried out in the course of their trade, profession or vocation

Box 14: days you worked for more than 3 hours overseas

The form labels box 14 “Number of days you worked for more than 3 hours overseas in 2025–26”.[2] The notes say only this:

This box does not need to be completed as part of making an election or claim to OWR.[1]

OWR is Overseas Workday Relief. HMRC doesn’t say more about box 14 in the notes. If your accountant asks for an overseas work-day figure, a daily work log covers it.

Box 54: the notes that go with the numbers

Box 54 is “Any other information”. The form says boxes 3, 3.1, 8, 11.1 and others may need more information there.[2]

The notes ask for:[1]

• the number of deemed days included in box 10
• the start and end dates of any gaps between employments (box 8)

The form’s list doesn’t name box 10. But the box 10 notes still ask for the deemed-days note.[1]

What records back up your SA109 numbers?

HMRC’s manual says you’ll need records and documents to support what you say about the SRT. Its lists are examples, not a complete set:[11]

• Where you spent your days and midnights: your travel schedule, booking information, and tickets and boarding cards, including e-tickets.[13]
• Work, if residence turns on the full-time work tests: the split of your working life between the UK and overseas, noting days you worked over 3 hours. A work diary, calendar or timesheet is likely to show the nature and duration of your work.[12]
• Exceptional circumstances: what the circumstances were, and what you did to mitigate (lessen) them where that was possible.[12]
• Homes: evidence such as utility bills, and credit card and bank statements that show the pattern and place of your day-to-day spending.[14]

The table maps those records to the boxes. It’s our suggestion, not an HMRC form. Accountants’ questionnaires vary, so ask yours what they want.

Most of this arrives scattered across inboxes, airline apps and bank statements. That’s how travel records come, not something you did wrong.

The job is gathering it into one dated record before the return is due. Then you read boxes 10 to 13 off one record instead of rebuilding them from scattered files. Nomad Pro keeps that record as a travel log and exports it to CSV or PDF for you or your adviser.

Our suggestion: mark days you can’t pin down as unclear. A flagged gap your adviser can check beats a guess entered as fact.

More on what to keep: what records HMRC says to keep and why documentation matters.

Frequently asked questions

Do days I was stuck in the UK because of illness go in box 10?

Yes, if you were in the UK at midnight. HMRC’s notes say exceptional circumstances days go in box 10, and their number also goes in box 11. Box 11 should not exceed 60.[1]

Where do transit days go?

In box 11.1, not box 10. The notes say not to include them in any entry in box 10.[1]

What are deemed days, and where do I show them?

They’re UK days without a midnight, beyond the first 30, that are treated as UK days when the deeming rule applies. Include them in box 10 and note how many in box 54, the notes say.[1][6]

Can I file the SA109 online with HMRC’s own service?

HMRC’s notes don’t mention HMRC’s own online service. They say to file online you’ll need to buy software from a commercial supplier, or authorise a professional agent. Don’t send the pages as an electronic attachment to an online return. GOV.UK lists commercial software suppliers.[1][15]

What are the deadlines for the 2025–26 return?

GOV.UK says paper returns must reach HMRC by 11:59pm on 31 October 2026. Online returns are due by 11:59pm on 31 January 2027. If you register for Self Assessment after 5 October 2026, HMRC’s letter or email gives a different filing deadline: 3 months from the date on it. You must still pay the tax you owe by 11:59pm on 31 January 2027.[4]

I’m claiming split year treatment. Which days go in box 10?

Only UK days in the overseas part of the year, the notes say. Split year cases have detailed conditions, so check this one with an adviser.[1]

Can Nomad Pro fill in my SA109?

No. Nomad Pro keeps your travel record and exports it to CSV or PDF. You or your adviser fill in and file the return.

Sources

Checked on 6 October 2026. This guide follows the 2025–26 SA109 notes, which GOV.UK lists as updated on 28 September 2026 (footer “HMRC 12/25”). Its change note says that update removed references to a source-by-source basis from the notes for boxes 28 and 29.

GOV.UK shows the Residence and FIG Regime Manual as published 4 April 2025 and last updated 3 July 2026. That date is for the whole manual, not a sign that any page listed here changed then.

1. HMRC: Residence and foreign income and gains (FIG) regime etc notes, 2025–26 (SA109 notes)
2. HMRC: SA109 form, 2025–26
3. GOV.UK: Residence and FIG regime etc (Self Assessment SA109)
4. GOV.UK: Self Assessment tax returns, deadlines
5. RFIG20710: Meaning of a day spent in the UK
6. RFIG20720: The deeming rule
7. RFIG20730: Transit days
8. RFIG22210: Exceptional circumstances, introduction
9. RFIG20580: Country tie
10. RFIG20740: Work for the purpose of the SRT
11. RFIG21910: Records that should be kept for SRT purposes
12. RFIG21930: Record keeping, working hours and location of work done
13. RFIG21940: Record keeping, the sufficient ties test
14. RFIG21920: Record keeping, home
15. GOV.UK: Self Assessment online, commercial software suppliers

Educational information, not tax advice. How you fill in your return depends on your own facts and current law. If your position is close to a threshold or commercially significant, use HMRC’s current notes and take advice from a qualified professional.