---
title: "The Accommodation Tie (SRT): UK & NZ Residency Rules Explained"
description: When advising clients on their United Kingdom tax residency under the Statutory Residence Test (SRT), evaluating the Sufficient Ties Test is paramount for individuals who fail the automatic overseas and UK tests. The Accommodation Tie (SRT) is one of the…
url: "https://www.accountingfirms.co.uk/knowledge-bank/the-accommodation-tie-srt-uk/"
updated: "2026-08-11"
category: "Expat & Non-Resident Tax"
---

# The Accommodation Tie (SRT): UK & NZ Residency Rules Explained

When advising clients on their United Kingdom tax residency under the Statutory Residence Test (SRT), evaluating the Sufficient Ties Test is paramount for individuals who fail the automatic overseas and UK tests. The Accommodation Tie (SRT) is one of the most frequently triggered connections, often catching out expatriates and frequent travellers.

This guide breaks down the precise statutory mechanics of the accommodation tie in the UK, while offering comparative context on how New Zealand handles accommodation-based residency tests.

## The UK Statutory Mechanics

Under the UK Statutory Residence Test, an individual establishes an Accommodation Tie (SRT) for a given [tax year](https://www.accountingfirms.co.uk/blog/good-timing-can-save-a-lot-of-tax/) if they have a place to live in the UK that is available to them for a continuous period of at least 91 days.

However, mere availability is not enough to trigger the tie; actual usage is required. The taxpayer must spend at least one night in that accommodation during the [tax year](https://www.accountingfirms.co.uk/blog/its-that-time-again-year-end-tax-planning/).

| Condition | Threshold Requirement |
| --- | --- |
| **Availability** | Available for a continuous period of 91 days or more during the [tax year](https://www.accountingfirms.co.uk/knowledge-bank/basis-period-reform-a-practical-guide/). |
| **Standard Usage** | The individual spends at least 1 night in the [property during the tax](https://www.accountingfirms.co.uk/property-tax-calculator/) year. |
| **Close Relative Usage** | The individual spends at least 16 nights in the property (if it is the home of a close relative). |

### The "Close Relative" Exception

A strict exception applies if the accommodation is the home of a close relative. If the property belongs to a close relative, the individual must spend at least 16 nights there during the tax year to trigger the tie.

[HMRC applies](https://www.accountingfirms.co.uk/blog/sa302-tax-calculation/) a strict definition to "close relative. For the 16-night rule, it includes parents, grandparents, siblings, and adult children or grandchildren.  It explicitly excludes cousins, friends, and other distant relatives.

## A Comparative Perspective: New Zealand's "Permanent Place of Abode"

For clients moving between the UK and New Zealand, it is crucial to understand that New Zealand [tax law](https://www.accountingfirms.co.uk/blog/how-to-manage-stress-during-tax-season/) does not employ a mechanical day-counting tie system for accommodation.

Instead, section YD 1(2) of the [Income Tax](https://www.accountingfirms.co.uk/blog/hmrc-payment-niers/) Act 2007 (NZ) states that a natural person is a New Zealand resident if they have a "permanent place of abode" (PPOA) in New Zealand.

> "Despite anything else in this section, a natural person is a New Zealand resident if they have a permanent place of abode in New Zealand, even if they also have a permanent place of abode elsewhere."

Inland Revenue and the courts require a highly factual, qualitative assessment. In the leading Court of Appeal case *CIR v Diamond* [2015] NZCA 613, the court ruled that a permanent place of abode requires an integrated factual assessment of dwelling-specific enduring ties, focusing on whether a place operates as a true "home".  Merely owning an [investment property](https://www.accountingfirms.co.uk/knowledge-bank/can-an-spv-be-used-for-property-investment-in-the-uk/) that you have never lived in does not create a PPOA.

However, as highlighted in *Case Q55*, the dwelling does not need to be constantly vacant and waiting for the taxpayer; it merely needs to be available as a home when the taxpayer requires it, coupled with a durable connection to the locality.

 

*Consider researching how the 91-day continuous availability rule under the SRT operates across consecutive tax years, and whether gaps of fewer than 16 days break the continuity for The Accommodation Tie (SRT).*