Rule reference

HMRC Rule Reference & Day-Count Mechanics.

A factual reference to how HMRC’s Seafarers’ Earnings Deduction rules count days, with links to the official HMRC sources for each one.

Educational Reference Only: This section explains how HMRC day-count mechanics operate for record-keeping purposes. easySED is a record-keeping tool, not tax advice. Every seafarer’s circumstances are unique; always verify your eligibility and claim details with a qualified tax professional or accountant before submitting a return.

1Eligible period

The 365-Day Qualifying Period & the Midnight Rule

Seafarers’ Earnings Deduction is set out in section 378 of the Income Tax (Earnings and Pensions) Act 2003. One of its conditions is an eligible period: a period of at least 365 days made up mainly of days of absence from the UK.

How HMRC defines a “day of absence”

Days are not counted by where you spend most of the day. They are counted by where you are when the day ends.

“You’re absent from the UK on a particular day if you’re outside the UK at midnight at the end of that day.”HMRC Helpsheet HS205

As a result, the day of departure counts as a day of absence and the day of return does not. HMRC’s guidance treats casting off from a UK berth as the time of departure for a voyage that begins or ends outside the UK. The guidance refers to midnight at the end of the day; it does not set out separate rules for time zones.

Being on duty is not part of the test. A rest day, leave day or standby day spent outside the UK at midnight is a day of absence in the same way as a working day.

Worked example

A seafarer leaves the UK on Monday morning and lands back in the UK on Saturday evening. They are outside the UK at midnight at the end of Monday, Tuesday, Wednesday, Thursday and Friday: 5 days of absence. Saturday is a UK day, because they are in the UK at midnight.

Return visits within the period

The 365 days do not have to be spent continuously abroad. Under HS205, a return visit to the UK can form part of the eligible period when both of the following apply:

  • no single return visit lasts for more than 183 consecutive days, and
  • total UK days stay within the half-day rule (see Article 2).

A return visit only counts when it falls between two periods of absence. UK days at the end of a run of absence days do not extend the period.

Educational reference only, summarising published HMRC guidance. Not tax advice. Confirm how these rules apply to your circumstances with a qualified tax professional.

2UK days

The Mechanics of the Half-Day Rule

The half-day rule limits the share of an eligible period that can be spent in the UK. HS205 states that a return visit can count towards the eligible period if:

“the total number of days you’ve spent in the UK is not more than one-half of the total number of days from your first day abroad to the last day of the period you spent abroad after that return visit”HMRC Helpsheet HS205

How the threshold is measured

  • The test is cumulative. It is measured from the first day abroad at the start of the period, not visit by visit.
  • It is applied again after each return visit. The count runs to the end of the period abroad that follows that visit.
  • The condition is UK days ≤ ½ × total days. A result exactly equal to half still meets it.
  • The 183-consecutive-day limit on any single visit applies in addition to this test.

In plain terms: each time a UK visit ends and the next spell abroad finishes, add up every day since the period began. No more than half of those days can be UK days.

Example A: the rule is met

100 days abroad60 in the UK70 abroad50 in the UK90 abroad

Check 1: after the first UK visit and the 70 days abroad that follow

All days so far
100 + 60 + 70 = 230
Most UK days allowed (half)
115
UK days so far
60

60 is no more than 115, so the rule is met.

Check 2: after the second UK visit and the 90 days abroad that follow

All days so far
230 + 50 + 90 = 370
Most UK days allowed (half)
185
UK days so far
60 + 50 = 110

110 is no more than 185, so the rule is met.

Result: both checks are met and the period covers 370 days, which reaches the 365-day minimum.

Example B: the rule is broken

100 days abroad60 in the UK70 abroad150 in the UK20 abroad

The start is the same as Example A, but the second UK visit is much longer.

Check 1: the same as Example A

All days so far
230
Most UK days allowed (half)
115
UK days so far
60

The rule is met.

Check 2: after the 150-day UK visit and the 20 days abroad that follow

All days so far
230 + 150 + 20 = 400
Most UK days allowed (half)
200
UK days so far
60 + 150 = 210

210 is more than 200 (10 days over), so the rule is broken.

Result: the 150-day visit cannot count towards the period. The period stops after the 70 days abroad, at 230 days, so it does not reach 365. The 150-day visit is within the 183-day limit, so it is the half-day rule alone that breaks the period here.

Educational reference only. The worked examples are illustrative and use simplified figures. Not tax advice. Confirm how these rules apply to your circumstances with a qualified tax professional.

3Voyages

Foreign Port Visits & Qualifying Voyages

SED applies to the earnings from an employment whose duties are performed wholly or partly outside the UK. For duties performed on a ship, HMRC defines “outside the UK” by reference to where the voyage begins and ends.

“The employment duties of a seafarer are regarded as being performed outside the UK if they are carried out on a vessel that’s engaged on a voyage or part voyage which begins or ends outside the UK.”HMRC Helpsheet HS205

How HMRC applies this

  • A voyage, or part of a voyage, that begins or ends at a port outside the UK is treated as performed outside the UK.
  • Any part of a voyage that both begins and ends in the UK is excluded.
  • HMRC’s internal manual states that voyages which do not involve a call at an overseas port do not qualify. Sailing beyond UK territorial waters alone is not enough.
  • For the location of duties, the UK includes its 12-mile territorial sea and the designated areas of the UK continental shelf, such as the UK sector of the North Sea. Under HMRC’s manual, days spent in those designated areas are still treated as days of absence when counting the eligible period.

Example from HMRC guidance

A trawler sails from the UK and docks at a port in Iceland to unload its catch. Duties performed on the voyage from the UK to Iceland, and from Iceland back to the UK, are treated as performed outside the UK.

HMRC’s published guidance frames this as a test of each voyage. It does not set a minimum number of foreign port visits per tax year. Keeping a record of the foreign ports called at on each voyage helps show which duties fall within this definition.

Educational reference only. Whether a particular vessel or voyage qualifies depends on the facts. Offshore installations, for example, are excluded. Not tax advice. Confirm with a qualified tax professional.

4HMRC documents

What Is an HS205 Working Sheet?

HS205 (Seafarers’ Earnings Deduction) is a Self Assessment helpsheet that HMRC publishes for each tax year. It explains the SED conditions and includes a working sheet: a structured table for summarising day counts.

What the working sheet records

  • Each period abroad, as a start date and an end date.
  • Each return visit to the UK in between, with the number of UK days.
  • Running totals that apply the 183-day and half-day tests after each return visit.

HMRC uses this table to establish whether an eligible period of 365 days or more exists, and over which dates it runs. In HMRC’s words: “Use the working sheet if you’ve an eligible period of 365 days or more.” The resulting figures relate to the tax return for that year.

Supporting documents

“You should keep your discharge book and all other documents which support your claim. Do not send them with your tax return.”HMRC Helpsheet HS205

HMRC may ask to see these documents later. They include discharge book entries, travel tickets and boarding passes, payslips and crew agreements.

Where easySED fits

The working sheet is only as accurate as the dates entered into it. easySED keeps a running log of the underlying data as you travel: departure and return dates, days of absence, UK visits and copies of supporting evidence. It can export that log as a summary to review alongside the official HS205 working sheet with your accountant. easySED does not complete or submit HMRC forms. The digital copies it holds sit alongside your original documents and do not replace them.

Educational reference only. HMRC updates HS205 each tax year, so always use the version for the relevant year. Not tax advice. Have a qualified tax professional or accountant review your figures before any return is submitted.

Further reading

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