The Country Tie only applies to individuals who have been resident in the UK in any of the three fiscal years preceding the relevant year.601 An individual will have a Country Tie for a year ‘if the country in which [he] meets the midnight test for the greatest number of days in [the relevant year] is the UK’.602

He will also have a Country Tie if:

(a)he meets the midnight test for the same number of days in the relevant year in two or more countries;

(b)that number is the greatest number of days for which he meets the midnight test in any country in the relevant year;

(c)one of those countries is the UK.603

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