SA109 Explained Box by Box: The Residence Pages (2025-26)

The SA109 - "Residence and foreign income and gains (FIG) regime etc" - is where everything the Statutory Residence Test decided about you gets reported to HMRC. Non-residence, split year treatment, your day counts, your tie count, FIG regime claims: it all lands on these four pages, filed as part of your Self Assessment return.

Two things surprise people. First, you cannot file it through HMRC's own online service - the SA109 goes on paper (deadline 31 October) or through commercial software (31 January). Second, the form doesn't ask whether you are non-resident in any explanatory way - it asks for the raw SRT facts: days, ties, work days, dates. The form is easy; knowing your numbers is the work.

(Filing a P85 instead? Then you shouldn't be here - check which form you need.)

Key points

• SA109 is a supplement to the SA100 return, not a standalone form
• Boxes 1-14 are pure SRT output: residence status, split year, day counts, ties, work days
• Box 3 + box 6 carry a split year claim; the case goes in box 54
• Day counting follows the midnight rule (RFIG20710) with exceptional-circumstances days (max 60) split out into box 11
• From 2025-26 the form reflects the FIG regime that replaced the remittance basis

Boxes 1-14: residence status

This is the section that matters for most leavers and arrivers, and every entry is an SRT fact.

Box 1 - not resident. An X here claims non-residence for 2025-26. It has to be true under the SRT - the automatic overseas tests or the sufficient ties test - not just true in spirit. (Box 2 is not in use.)

Box 3 and box 3.1 - split year treatment. Box 3 claims that your circumstances meet one of the split-year cases; box 3.1 flags that more than one case applies. There is no standalone split-year form - this is where the claim lives. State which case in box 54; if more than one applies, the SRT's priority ordering decides which governs your split date.

Box 4 - resident in 2024-25. Prior-year residence feeds several split-year cases and decides whether you are a "leaver" or "arriver" for the ties table.

Box 6 - the split date. The date the UK part of the year begins or ends. This single date decides which side of the line every pound of income falls on, and it comes out of the specific split-year case - it is not simply your travel date.

Box 7 - third automatic overseas test. An X if you work full-time overseas within the test's limits (the detail here).

Box 8 - gap between employments. Relevant to the full-time-overseas-work calculation; explain in box 54.

Box 9 - overseas home.

Box 10 - days in the UK. The headline number: days you were present in the UK at midnight during 2025-26 (RFIG20710). The day you leave is normally not a UK day; the day you arrive back is.

Box 11 - exceptional circumstances. Of the box 10 days, how many are attributed to exceptional circumstances (serious illness, national emergencies) - capped at 60 days per tax year, and narrower in practice than people hope.

Box 11.1 - transit days. Midnights in the UK while in transit between two other countries, provided you did nothing unrelated to travel - excluded from box 10, reported here instead.

Box 12 - your ties. The count from the UK ties test: family, accommodation, work, 90-day and (for leavers) country tie.

Boxes 13 and 14 - work days. Days you worked more than 3 hours in the UK (box 13) and overseas (box 14). These underpin box 7 and the work tie, and they are the numbers least likely to survive being reconstructed from memory in an enquiry.

If you have been tracking the year as it happened, boxes 10-14 are a read-out, not a research project. That is, frankly, the argument for tracking: the day planner keeps the box 10 count honest through the year, and the split year dashboard works through which case applies and what date belongs in box 6.

Boxes 15-24: allowances, other residences, treaties

Boxes 15-17 claim personal allowances as a non-resident - box 15 where a double taxation agreement entitles you, box 16 on other grounds (nationality, EEA residence and similar; explain in box 54), box 17 the country codes.

Boxes 18-19 record the other countries where you were tax resident in 2025-26 (and 2024-25). Boxes 20-22 carry double-taxation relief claims - box 21 for treaty residence awarded to another country (Helpsheet 302), box 22 for other treaty provisions (Helpsheet 304); both need the helpsheet claim form attached.

Boxes 23-24 are for arrivers: date of arrival and the last prior year of UK residence. (Boxes 25-27 are not in use.)

Boxes 28-53: FIG regime, OWR, and the old remittance basis

From 6 April 2025 the foreign income and gains (FIG) regime replaced the remittance basis: qualifying new arrivals can claim relief on foreign income and gains for their first 4 years of UK residence. Boxes 28-30 carry that claim (box 30 for the qualifying-asset-holding-company edge case).

Boxes 37-39 are legacy remittance-basis boxes - nominated income remitted this year, business investment relief - relevant only if you have pre-April-2025 amounts still in the system. Boxes 40-49 handle Overseas Workday Relief elections, claims and the financial limit; boxes 50-53 the temporary repatriation facility for bringing previously-sheltered amounts to the UK at the reduced rate.

Most leavers never touch this section. If you genuinely do, this is also where "read a blog post" stops being an adequate preparation - these regimes reward professional advice.

Box 54: the box the form keeps pointing at

"Any other information" sounds optional. It isn't: the form itself says boxes 3, 3.1, 8, 11.1, 16, 37, 38, 39, 51, 52 and 53 may require more information here. The most common miss is a split-year claim with no statement of which case is relied on - say the case, the key facts, and the date logic.

The mistakes that generate HMRC letters

• Filing through HMRC's online service and only then discovering it cannot include the SA109 - now it is late October and the paper deadline has passed; commercial software is the escape hatch
• Box 10 guesswork. Reconstructing a year of midnights from a calendar in January rarely matches border data
• Counting transit days twice - box 11.1 days do not also belong in box 10
• A bare X in box 3 with no case stated in box 54
• A box 6 date that is just the flight date rather than the date the applicable case actually produces

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This article describes what the 2025-26 SA109 boxes ask, based on the published form and notes - it is not advice on what you should claim. Dual residence, treaty positions, FIG/OWR claims and anything contentious belong with a professional adviser.