I'd been hoping that days where you arrived AND departed on the same day would not be counted, giving a much better chance of staying within the 90 day rule. Admittedly coming over to the UK the night before an early duty would be a difficulty but hopefully you could balance those with enough days where you could arrive and depart on the same day. Now that these days are also to be counted, anyone living abroad could be deemed resident simply by spending a few hours per week in an airport. Staying airside isn't an option since airline offices which one would need to visit are on the 'public side'.
This is not in the spirit of paying a 'fairer share' and I've sent off an email pointing out why this draft legislation is most unfair to pilots. I'd urge others to do the same.
This is money grabbing in true Gordon Brown red labour fashion. Taxing people who receive none of the benfefits that this taxation provides. No schooling, no NHS, no local and national services etc etc. How than this possibly be construed as fair???