{
  "publisher": {
    "name": "Provedays",
    "url": "https://provedays.com"
  },
  "license": "CC BY 4.0",
  "license_url": "https://creativecommons.org/licenses/by/4.0/",
  "attribution": "Provedays — provedays.com",
  "notice": "Rule data is licensed CC BY 4.0. Golden test fixtures, guide prose and the rule schema are not covered by this licence and remain all rights reserved. See https://provedays.com/terms/.",
  "documentation": "https://provedays.com/methodology/",
  "rule_id": "gb.sct.taxpayer",
  "versions": [
    {
      "rule_id": "gb.sct.taxpayer",
      "version": "2026.1",
      "jurisdiction": "GB-SCT",
      "title": "Scottish taxpayer status",
      "summary": "Scottish taxpayer status for a UK-resident individual: a close connection with Scotland (main place of residence), or — only when there is no close connection with any part of the UK — more days spent in Scotland than in EACH of England, Wales and Northern Ireland separately, counted by where you are at the end of the day. Ties fail. Sets which nation's income tax rates apply to your non-savings income for the WHOLE tax year.",
      "evaluator": "composite_conditional",
      "determinative": true,
      "official_source_url": "https://www.legislation.gov.uk/ukpga/1998/46/section/80F",
      "last_verified": "2026-08-30",
      "effective_from": "2016-04-06",
      "effective_to": null,
      "disclaimer_level": "standard",
      "convention": {
        "midnight_rule": true,
        "transit_excluded": true
      },
      "params": {
        "reference_period": {
          "type": "tax_year",
          "start_month": 4,
          "start_day": 6
        }
      },
      "logic": {
        "all": [
          {
            "attestation": "gb.nations.uk_resident"
          },
          {
            "any": [
              {
                "attestation": "gb.nations.close_connection",
                "equals": "scotland"
              },
              {
                "all": [
                  {
                    "attestation": "gb.nations.close_connection",
                    "equals": "none"
                  },
                  {
                    "compare_counts": {
                      "target": {
                        "country": "GB-SCT"
                      },
                      "against": [
                        {
                          "country": "GB-ENG"
                        },
                        {
                          "country": "GB-WLS"
                        },
                        {
                          "country": "GB-NIR"
                        }
                      ],
                      "op": ">"
                    }
                  }
                ]
              }
            ]
          }
        ]
      },
      "attestation_defs": [
        {
          "key": "gb.nations.uk_resident",
          "question": "Were you UK tax resident for this tax year under the Statutory Residence Test?",
          "why_we_ask": "Scottish and Welsh taxpayer status only exists for UK residents (Scotland Act 1998 s.80D(1)(a)). Your UK SRT counter answers this question.",
          "type": "bool",
          "scope": "tax_year"
        },
        {
          "key": "gb.nations.close_connection",
          "question": "In which part of the UK was your main place of residence this tax year — or 'none' if you had no main place in any one part?",
          "why_we_ask": "A close connection with one part of the UK decides taxpayer status BY ITSELF (s.80E) — the day count is legally irrelevant unless you had no close connection with any part. Main place of residence is a facts question only you can answer.",
          "type": "choice",
          "choices": [
            "scotland",
            "wales",
            "england",
            "northern_ireland",
            "none"
          ],
          "scope": "tax_year"
        }
      ],
      "notifications": [],
      "notes": [
        "Scotland Act 1998 s.80F(1): the number of days on which T is in Scotland at the end of the day must EXCEED EACH of the days in England, in Wales and in Northern Ireland — a separate comparison against every other nation, not against the rest of the UK combined. HMRC's own worked example (120 Wales / 100 England / 50 Scotland / 10 NI) makes a WELSH taxpayer despite 160 days elsewhere in aggregate. Ties fail: the statute requires 'exceeds'.",
        "Counting basis: end-of-day (midnight) presence, per STTG4500 — arrival and departure days count only toward the nation where you are at the end of the day; a same-day in-and-out of Scotland with the night spent elsewhere scores nothing for Scotland.",
        "Transit exclusion (s.80F(2)): a day counts for NO nation when you arrive as a passenger, leave the next day, and between arrival and departure do not engage in activities substantially unrelated to your passage. Label such days 'transit' in the calendar. HMRC's gloss: a hotel meal is fine; a work meeting or a cinema visit is substantially unrelated.",
        "This day count needs your UK days recorded at nation level (Scotland / England / Wales / Northern Ireland). Days recorded as bare 'United Kingdom' count toward no nation here.",
        "Not modelled: the parliamentarian limb (s.80D(1)(c)) — a Scottish parliamentarian is a Scottish taxpayer regardless of days, and that status also blocks Welsh taxpayer status (mutual disapplication).",
        "Status applies to the whole tax year — there is no split year for this limb (STTG4100)."
      ]
    }
  ]
}