The non-resident landlords scheme (NRLS) is a form of withholding tax arrangement for taxing UK rental income of persons whose ‘usual place of abode’ is outside of the UK. Importantly in this context, ‘non-resident’ does not have the same meaning established by the statutory residence tests.

The term ‘usual place of abode’ is not defined in statute, but HMRC’s Property Income Manual at paragraph 4810 says:

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