Location Data in Tax Audits: Why It Matters for HNWIs

Location data in tax audits can protect HNWIs. As global tax authorities ramp up AI-driven investigations, even minor discrepancies in day counting can lead to major liabilities. This article explores real court cases and how platforms like Daysium help individuals stay compliant, confident, and audit-ready.
An image of the European map with a man and a suitcase standing on it, reflecting the importance of location data in tax audits.

As global mobility increases, so does scrutiny from tax authorities. For high-net-worth individuals (HNWIs), maintaining compliance is no longer just about filing on time. It’s about having a bulletproof record. Increasingly, the cornerstone of that record is location data.

With governments investing in advanced technologies to track movement, automate audits, and cross-reference digital footprints, location data in tax audits can actually protect HNWIs. In this article, we examine why and how through real case studies. We’ll also explore all the ways Daysium enables HNWIs to stay ahead.

The Rising Use of AI and Data Analytics by Tax Authorities

Around the world, tax agencies are embracing artificial intelligence, machine learning, and automated systems to detect non-compliance, often before taxpayers even know they’re under review.

  • HMRC’s ‘Connect’ system analyses over 30 different databases—credit card transactions, property records, social media, and more—to identify discrepancies in tax filings.
  • CIAT cites a  2023 OECD report that claims more than 80% of tax administrations are either using or implementing advanced AI techniques.
  • Mexico uses machine learning to scan electronic invoices and networked transactions, detecting evasion and flagging risks that traditional audits might miss.

This tech-driven approach means that even unintentional errors, like miscounting your days, can trigger a full investigation.

Why HNWIs Are a Target

The latest data suggests that HNWIs contribute just 4% (£1.9 billion) of the UK’s total tax gap. HMRC has also increased its compliance yield from wealthy individuals from £2.2 billion in 2019/20 to £5.2 billion in 2023/24. This shows these audits are a priority to the tax authority. 

The UK’s High-Risk Wealth Programme (HRWP) targets individuals with assets over £2 million or income over £200,000. These individuals often have complex, cross-border affairs, and even small mistakes in day counting can lead to significant liabilities.

When Day Counts Alone Aren’t Enough: Real-World Case Studies

Case A: The Irish Numismatist

In Case 177TACD2020, a numismatist needed to prove he wasn’t in Ireland for more than 183 days in any given year from 2002 to 2006. His case hinged on receipts and card transactions, but the Appeal Commissioner ruled these were insufficient. A car rental proved only that “the appellant had occasionally rented a car,” not that he had left the country.

Case B: The Commuter from Northern Ireland

In 08TACD2020, a UK citizen commuting to work in Ireland found themselves entangled in a complex web of split residence rules, elective declarations, and inadequate documentation. While he eventually prevailed, the lack of contemporaneous evidence prolonged the process.

Case C: Kevin McCabe v HMRC

UK businessman Kevin McCabe claimed to have moved to Belgium yet retained deep UK ties through property, business operations, and frequent travel. The court found that these ties undermined his non-residence claim, resulting in a significant tax liability.

Case D: A Taxpayer v HMRC [2025] EWCA Civ 106

In this recent UK case, a taxpayer breached the 45-day limit under the Statutory Residence Test due to caring for her twin sister. The legal journey began in 2022, with the Court of Appeal overturning an earlier Upper Tribunal ruling in February 2025. In this drawnout case, the quality of evidence was called into question.

These cases all demonstrate the same thing: day counts are not enough. You need real-time, verifiable data to prove where you were and why.

The Power of Location Data in Tax Audits

Location data bridges the gap between claim and proof. Here’s how:

1. It’s Contemporaneous

Tax authorities value records created at the time of the event. Geo-tagged photos, GPS logs, and timestamped entries provide the kind of evidence that holds up in court.

2. It Corroborates Self-Reported Claims

If you say you weren’t in the UK for more than 90 days, a spreadsheet won’t cut it. However, GPS records, combined with boarding passes and event photos, can.

3. It Shortens Investigations

Audits are prolonged when data is patchy or inconsistent. With clear records, cases are easier to close. This saves time, reduces stress, and keeps legal fees under control.

The Daysium Advantage: Tax Residency Protection in a Digital Era

Daysium transforms location data into a strategic compliance asset in tax audits. Here’s how:

Automated Day Counting

Daysium’s companion app logs a user’s location passively and accurately. No need to remember where you were as your phone remembers for you.

Custom Tax Rulesets

Users select bespoke tax rules (or “Rulesets”) based on their advisor’s guidance. These govern allowable days and automatically alert the user as thresholds approach.

Evidence Integration

Users can attach geo-tagged documents (such as boarding passes, photos, and notes) to each travel event. This turns a day count into a legally defensible record.

Long-Term, Secure Records

Daysium encrypts and stores records securely, ensuring access if a tax authority looks back five or even ten years, as in the Irish court cases.

A Global Trend Toward Transparency

The world is moving toward automatic transparency:

  • The OECD’s Automatic Exchange of Information (AEOI) programme shared details on 123 million bank accounts across jurisdictions in 2022.
  • HMRC opened nearly 300,000 compliance investigations in the UK during the 2022/23 financial year.

Daysium’s partner tax specialists report a sharp rise in cross-border scrutiny and requests for location-based proof.

As one of Daysium’s Founding Partners, Stephanie Wickham of Expat Taxes puts it:

“Tax authorities are increasingly using more sophisticated data analysis in their audit interventions and risk management. So for clients that frequently cross borders a platform such as Daysium is invaluable in ensuring that a solid evidence book can be presented in the event of a Revenue enquiry/intervention.”

Conclusion: Compliance, Clarity, Confidence

Tax audits are changing. Authorities don’t just want your numbers on a spreadsheet. They want the story behind them. By presenting location data in tax audits, you make that story provable.

HNWIs who maintain precise records using tools like Daysium don’t just stay compliant but they gain peace of mind. They can plan future travel with confidence, knowing their residency status is backed by real-time data, not assumptions. And if the authorities come asking questions, they have the confidence to state, “There’s nothing to see here. Everything is in order.” 

Don’t let missing evidence be your downfall. Let Daysium turn your travel history into a protective shield. Book a discovery call today.

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