Medical.Accountants
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Tax guides

IR35 for Locum Doctors & Nurses

Inside or outside IR35 - what it means for your take-home. Expert UK guide for locum doctors and nurses from ICAEW-regulated accountants. Updated for 2026/27.

Are NHS locum shifts inside IR35?

For locum engagements with NHS bodies, the hirer must decide IR35 status and issue a Status Determination Statement; the small-company exemption does not apply to public bodies. The test looks at control, substitution and mutuality of obligation in the actual working arrangement. You can ask the hirer to review a determination you disagree with, and it must respond within 45 days.

Fixed fees, specialist healthcare accountants, and every HMRC and NHS Pensions deadline handled.

  • Fixed monthly fee — no surprises
  • Specialist in NHS pension and healthcare tax
  • Onboarding within 48 hours
Get my fixed-fee quoteBook a free 15-min tax review
  • ICAEW & ACCA regulated
  • 5,000+ clients served by ACCOTAX
  • Specialist healthcare accountants

Reviewed by Waqas Sagar ACA FCCA FMAAT, Founder of ACCOTAX, 18+ years' experience · Last reviewed: 8 October 2026 · Updated for the 2026/27 tax year

Medical.Accountants by ACCOTAX, ICAEW/ACCA-regulated chartered accountants, London, serving clients across the UK. Over 5,000 clients served.

Key takeaways

  • Care and staffing businesses depend on accurate payroll, minimum wage compliance including travel time, auto-enrolment and VAT exemption conditions that hinge on regulation.
  • NHS bodies must issue a Status Determination Statement for each off-payroll engagement.

Free guide: The Doctor's Tax & NHS Pension Handbook 2026/27

Get the free guide

Which accountancy support fits your income?

Start with how you are paid. Different income sources can need different accounts, returns and expense checks.

How you workWhat we checkSupport to explore
Employed or umbrella (PAYE)Tax codes, eligible employment expenses and whether a tax return is needed.Healthcare tax refund support
Genuinely self-employedBusiness income and expenses, Self Assessment and MTD eligibility.Healthcare Self Assessment service
Your own limited companyCompany accounts, Corporation Tax, director income and off-payroll status where relevant.Healthcare limited company accounts
PartnershipPractice accounts, allocated profit and each partner’s personal tax position.Healthcare partnership accounts

Sound familiar?

Problems we fix for locum doctors

  • "I don't know if I should be a sole trader, a limited company or use an umbrella."
  • "A trust or agency has sent me an IR35 determination I don't understand."
  • "My first tax bill was huge because of payments on account."
  • "I keep missing or getting my locum A/B and Type 2 pension forms wrong."
  • "I spend hours chasing unpaid invoices."
  • "I'm not sure what I can claim — indemnity, GMC, mileage?"
  • "Making Tax Digital quarterly updates start from April 2026 and I'm not ready."

What it's costing you

Leaving it unfixed is rarely free

Overpaid tax
Unclaimed expenses and wrong tax codes mean paying more than you owe, year after year.
HMRC penalties and interest
Late returns attract automatic penalties, plus interest on tax paid late.
Lost evenings
Hours spent on forms, invoices and spreadsheets after a long shift.

General examples — your position depends on your own figures.

How we solve it

What we actually do for you

Structure review

A take-home comparison of sole trader, limited company and umbrella for your shifts.

IR35 check

We review each Status Determination Statement and help you challenge it where justified.

Pension form management

We prepare and track your locum A/B and Type 2 forms.

MTD-ready bookkeeping

Quarterly updates handled with software set up for you.

How we help

01

Accounts and tax returns

Year-end accounts and Self Assessment or company returns for ir35 for locum doctors & nurses, filed on time.

02

Fixed-fee advice through the year

Questions answered by your named accountant, without the clock running.

03

Making Tax Digital

Compatible software set up and quarterly updates filed where MTD applies.

04

NHS pension tax

Annual allowance and taper calculations, with Scheme Pays guidance where a charge arises.

What to know before you decide

Off-payroll rules in the NHS

Care and staffing businesses depend on accurate payroll, minimum wage compliance including travel time, auto-enrolment and VAT exemption conditions that hinge on regulation. Monthly management accounts show occupancy, staff cost ratios and cash flow early enough to act.

IR35 Reviews for Doctors & Healthcare Professionals

Status Determination Statements

This is one of the questions we work through with ir35 for locum doctors & nurses at the start of every engagement. We look at your real income, contracts and records, set out the options in plain English and confirm the work and fee in writing.

IR35 Reviews for Doctors & Healthcare Professionals

Disputing a determination

This is one of the questions we work through with ir35 for locum doctors & nurses at the start of every engagement. We look at your real income, contracts and records, set out the options in plain English and confirm the work and fee in writing.

Umbrella vs Ltd

NHS bodies must issue a Status Determination Statement for each off-payroll engagement. The decision turns on control, substitution and mutuality of obligation. Inside IR35 work is taxed like employment; outside work can be invoiced through a company. We review contracts, determinations and the effect on take-home pay.

IR35 Reviews for Doctors & Healthcare Professionals

Your questions answered

What is IR35?

For locum engagements with NHS bodies, the hirer must decide IR35 status and issue a Status Determination Statement; the small-company exemption does not apply to public bodies. The test looks at control, substitution and mutuality of obligation in the actual working arrangement. You can ask the hirer to review a determination you disagree with, and it must respond within 45 days.

Help with this question: IR35 Reviews for Doctors & Healthcare Professionals

Want us to check this for you? Get a free review →

Who decides whether my NHS work is inside IR35?

For locum engagements with NHS bodies, the hirer must decide IR35 status and issue a Status Determination Statement; the small-company exemption does not apply to public bodies. The test looks at control, substitution and mutuality of obligation in the actual working arrangement. You can ask the hirer to review a determination you disagree with, and it must respond within 45 days.

Help with this question: IR35 Reviews for Doctors & Healthcare Professionals

Want us to check this for you? Get a free review →

What is a Status Determination Statement?

For locum engagements with NHS bodies, the hirer must decide IR35 status and issue a Status Determination Statement; the small-company exemption does not apply to public bodies. The test looks at control, substitution and mutuality of obligation in the actual working arrangement. You can ask the hirer to review a determination you disagree with, and it must respond within 45 days.

Help with this question: IR35 Reviews for Doctors & Healthcare Professionals

Want us to check this for you? Get a free review →

Can I challenge an inside-IR35 determination?

For locum engagements with NHS bodies, the hirer must decide IR35 status and issue a Status Determination Statement; the small-company exemption does not apply to public bodies. The test looks at control, substitution and mutuality of obligation in the actual working arrangement. You can ask the hirer to review a determination you disagree with, and it must respond within 45 days.

Help with this question: IR35 Reviews for Doctors & Healthcare Professionals

Want us to check this for you? Get a free review →

Why is my first tax bill as a locum so high (payments on account)?

Your first bill often includes the tax for the previous year plus the first payment on account for the following year. Payments on account are due on 31 January and 31 July. Each payment is normally half of the previous year's total tax liability. This can effectively result in paying 150% of your tax in one go.

Check the official guidance · www.gov.uk

Help with this question: Self Assessment Tax Returns for Doctors & Healthcare Professionals

Want us to check this for you? Get a free review →

How does inside IR35 affect my take-home pay?

For locum engagements with NHS bodies, the hirer must decide IR35 status and issue a Status Determination Statement; the small-company exemption does not apply to public bodies. The test looks at control, substitution and mutuality of obligation in the actual working arrangement. You can ask the hirer to review a determination you disagree with, and it must respond within 45 days.

Help with this question: IR35 Reviews for Doctors & Healthcare Professionals

Want us to check this for you? Get a free review →

Do locum doctors have to follow Making Tax Digital from April 2026?

Making Tax Digital for Income Tax applies from 6 April 2026 to sole traders and landlords whose qualifying income (gross self-employment plus property income) is over £50,000, falling to £30,000 from April 2027 and £20,000 from April 2028. PAYE salary does not count. Ir35 for locum doctors & nurses trading through a limited company or a partnership are not brought in yet. We set up compatible software and file the quarterly updates for you.

Help with this question: Bookkeeping & Making Tax Digital for Doctors & Healthcare Professionals

Want us to check this for you? Get a free review →

Is an umbrella company the same as being inside IR35?

For locum engagements with NHS bodies, the hirer must decide IR35 status and issue a Status Determination Statement; the small-company exemption does not apply to public bodies. The test looks at control, substitution and mutuality of obligation in the actual working arrangement. You can ask the hirer to review a determination you disagree with, and it must respond within 45 days.

Help with this question: IR35 Reviews for Doctors & Healthcare Professionals

Want us to check this for you? Get a free review →

Can locum doctors pay into the NHS Pension Scheme?

Most NHS doctors and many healthcare staff are members of the NHS Pension Scheme. Contributions are deducted through payroll, and locum or private work can count only through the correct forms. High earners should check the annual allowance each year, as pension growth can trigger a tax charge.

Check the official guidance · www.gov.uk

Help with this question: NHS Pension Tax & Annual Allowance for Doctors & Healthcare Professionals

Want us to check this for you? Get a free review →

Do IR35 rules apply to private sector locum work?

For locum engagements with NHS bodies, the hirer must decide IR35 status and issue a Status Determination Statement; the small-company exemption does not apply to public bodies. The test looks at control, substitution and mutuality of obligation in the actual working arrangement. You can ask the hirer to review a determination you disagree with, and it must respond within 45 days.

Check the official guidance · www.gov.uk

Help with this question: IR35 Reviews for Doctors & Healthcare Professionals

Help with this question: VAT Registration & Returns for Doctors & Healthcare Professionals

Want us to check this for you? Get a free review →

What documents do I need for my return?

You typically require P60s, P11D forms, interest certificates, and records of all business income and expenses. Medical.Accountants provides a tailored checklist based on your specific healthcare role. We will request these details during our onboarding process. Providing comprehensive documentation ensures your tax position is accurately calculated.

Want us to check this for you? Get a free review →

What are payments on account?

Payments on account are advance payments towards your next Self Assessment bill, normally due on 31 January and 31 July. Each is usually half the previous year’s relevant Income Tax and Class 4 National Insurance bill, excluding Capital Gains Tax and student loans. Exceptions apply where the bill is below £1,000 or over 80% was collected at source.

Check the official guidance · www.gov.uk

Help with this question: Self Assessment Tax Returns for Doctors & Healthcare Professionals

Want us to check this for you? Get a free review →

Can I amend a return after filing?

You can generally amend a Self Assessment return within 12 months of the 31 January filing deadline. This allows you to correct errors or include forgotten information. Medical.Accountants can assist in reviewing previous submissions to ensure accuracy. Tax refunds can be claimed for up to four previous tax years.

Check the official guidance · www.gov.ukWant us to check this for you? Get a free review →

Quick quote

See what you could save — get a fixed fee in one working day

Three fields. No obligation. A specialist replies, not a sales team.

Packages for your working life

Accountancy packages for locum nurses

Self-employed income, a limited company, PAYE or a mixture: start with the support that matches how you actually work. We check your status and agree the scope and fee before starting.

Self-employed accountants for locum nurses packages

For genuine sole-trader income. We prepare your business accounts and Self Assessment, review allowable expenses and explain payments on account.

  • Sole-trader accounts and personal tax return
  • Allowable business expenses reviewed
  • Tax reserve and payment deadline guidance
  • MTD support scoped separately where required

Fixed fee quoted after a review

Discuss this package

Limited company accountants for locum nurses packages

For clinicians working through their own company. Choose Essential/Compliance, Core/Complete or Growth according to your accounts, bookkeeping and payroll needs.

  • Statutory accounts and Corporation Tax return
  • One director return for salary and dividends from the same company
  • Confirmation statement support; filing fee extra
  • Bookkeeping, VAT and payroll according to your chosen plan

Company packages from £45.83 + VAT / month

Compare company packages

Personal tax return packages for locum nurses

For employed clinicians, partners and people with mixed income who need a return. We check whether Self Assessment is required and reconcile the relevant income, expenses and pension tax information.

  • Self Assessment requirement checked
  • PAYE and other income reconciled
  • Eligible employment expenses reviewed
  • Pension tax work agreed separately where needed

Fixed fee quoted after a review

Discuss this package

Employment status is determined by the facts, not the package you choose. PAYE, umbrella and partnership arrangements may also apply. A limited company does not override IR35 or off-payroll rules, and not every employed clinician needs a tax return.

Overpaid tax?

Tax refund support for locum nurses

We review tax codes, eligible professional expenses and overpaid tax, then prepare a claim where you qualify. A refund is not guaranteed; HMRC decides the claim.

£249 + VAT

For refunds up to £5,000, our fee is £249 plus VAT. For refunds above £5,000, add 5% of only the amount above £5,000 to the £249 fee. VAT applies to the total professional fee.

Example: a £6,000 refund means £249 + £50 = £299 plus VAT.

Professional fee, excluding VAT

£249

Ask about a tax refund

This illustrates the fee only, not whether you qualify or how much HMRC will refund. We agree the claim scope and payment terms before work starts.

What's included

Limited company packages — compare what's included

Essential/Compliance

For locums, salaried GPs and dentists with a limited company

from £45.83 + VAT /month

  • FRS 105 or FRS 102 1A statutory accounts
  • Corporation tax return (CT600) and tax computation
  • Confirmation statement preparation and filing support
  • One director Self Assessment return
  • Deadline reminders ahead of every filing date

Core/Complete

For private practice, consultants and associate dentists

from £62.50 + VAT /month

  • Everything in Essential/Compliance
  • Monthly bookkeeping and bank reconciliation
  • Quarterly Making Tax Digital VAT returns
  • Director payroll with RTI filing and pension submissions
  • Quarterly review call on numbers and tax position

Growth

For clinics, dental practices and growing medical teams

from £75.00 + VAT /month

  • Everything in Core/Complete
  • Payroll for up to five employees

Prices exclude VAT. Making Tax Digital quarterly updates available as an add-on. Compare fees

Why clinicians trust us

Chartered accountants who know the NHS

  • ACCOTAX has served over 5,000 clients.
  • Regulated chartered accountants (ICAEW and ACCA).
  • Founded by Waqas Sagar ACA FCCA FMAAT, with 18+ years' experience.

Reviewed by Waqas Sagar ACA FCCA FMAAT

Chartered accountant and founder of ACCOTAX. Last reviewed October 2026.

Get my fixed-fee quote

How it works

  1. 01

    Free call

    A 15-minute chat about your income, structure and deadlines.

  2. 02

    Onboarding in 48 hours

    We set up your records, software and HMRC agent access.

  3. 03

    We handle the rest

    HMRC, NHS Pensions and every deadline, with reminders before each one.

Free resource

Get the locum expenses checklist free

Tell us where to send it and we'll email it to you.

Your questions, answered

Are NHS locum shifts inside IR35?
For locum engagements with NHS bodies, the hirer must decide IR35 status and issue a Status Determination Statement; the small-company exemption does not apply to public bodies. The test looks at control, substitution and mutuality of obligation in the actual working arrangement. You can ask the hirer to review a determination you disagree with, and it must respond within 45 days.
Can I challenge an IR35 determination?
For locum engagements with NHS bodies, the hirer must decide IR35 status and issue a Status Determination Statement; the small-company exemption does not apply to public bodies. The test looks at control, substitution and mutuality of obligation in the actual working arrangement. You can ask the hirer to review a determination you disagree with, and it must respond within 45 days.
How much does an accountant for locum doctors and nurses cost?
Our packages for ir35 for locum doctors & nurses start at £45.83 + VAT a month, with Core at £62.50 and Growth at £75 + VAT. The right package depends on your income sources, whether you trade through a company and any payroll, VAT or pension work. We confirm the exact fee in writing before any work begins, so there are no surprise invoices.
Do locum doctors and nurses need to comply with Making Tax Digital?
Making Tax Digital for Income Tax applies from 6 April 2026 to sole traders and landlords whose qualifying income (gross self-employment plus property income) is over £50,000, falling to £30,000 from April 2027 and £20,000 from April 2028. PAYE salary does not count. Ir35 for locum doctors & nurses trading through a limited company or a partnership are not brought in yet. We set up compatible software and file the quarterly updates for you.
How do I switch to Medical.Accountants?
Switching takes minutes on your side. You sign our engagement letter, we contact your previous accountant for professional clearance and records, and we take over HMRC and Companies House authorisations. You can switch mid-year; we pick up from the last filed return.

Speak to a specialist today

Leave your details and we'll call you back, or book a free review straight away.

Book a free 15-min tax review

Related healthcare expertise

IR35 Reviews for Doctors & Healthcare ProfessionalsNHS Pension Tax & Annual Allowance for Doctors & Healthcare ProfessionalsVAT Registration & Returns for Doctors & Healthcare ProfessionalsAccountants for doctors and GPs in the UKLocum doctor accountants: tax, IR35 and NHS pensions
Accountants for healthcare professionalsHealthcare tax questions answered

General information for the 2026/27 tax year, prepared from the official guidance linked below. It is not personalised tax or regulated financial advice. Rules and circumstances can change; confirm your position before acting.

Official sources referred to on this page: HMRC off-payroll working rules (GOV.UK); HMRC Check Employment Status for Tax (CEST); NHS Employers IR35 guidance; HMRC: Self Assessment & self-employment (GOV.UK); HMRC off-payroll working (IR35) guidance; NHSBSA: Pensions for locums; HMRC Making Tax Digital for Income Tax.

Official guidance

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