Hi david T
As stated by yourself, RDRM11340 is open to interpretation to an extent.
We would reinforce that although your query does not consist of a query regarding income from property or corresponding expenses, at a base level, we would advise that this refers to if there was a period of 91 consecutive days when you had a home in the UK.
On a more specific level, HMRC are not responsible for the decision of residency status, which ultimately must be decided by yourself if certain criteria are met within RDR3.
Notes may be found here:
RDR3: Statutory Residence Test (SRT) notes.
Thank you.