A user can be an individual, company or any other legal person. A UK user should be normally resident in the UK and primarily located in the UK when participating in the relevant business activity (or considered so, on a just and reasonable basis, where the UK user is travelling across borders).
It is important to note that the user’s location is based on their usual location, rather than their location at the time of the transaction which gives rise to relevant revenues.
Only revenues that arise through the engagement and participation of a UK user base will treated as UK revenues for DST purposes. For online advertising, UK revenues will comprise the revenue derived from adverts displayed at UK users. For other mediums, such as subscriptions, commissions etc., UK revenues will be those payments that come from a UK user or relate to a transaction involving at least one UK user.
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