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Contractor accounting

Specialist accountants for locum doctors and NHS contractors.

Locum doctors and NHS contractor physicians face the most complex combination of income sources, pension considerations and IR35 exposure in contracting. The NHS pension, the annual allowance tapering at high incomes, and the off-payroll rules that have applied to NHS trusts since 2017 all interact in ways that require specialist planning.

£80–£200/hr
Typical locum doctor rate range
Higher
IR35 risk (NHS has applied rules since 2017)
£60k
Annual pension allowance (2024/25)

The specific challenges

What makes NHS locum doctors different.

Off-payroll rules in the NHS since April 2017

NHS trusts and boards have been responsible for IR35 status determinations since April 2017. Many locum doctors were moved to inside IR35 arrangements at that point, either through PAYE or under NHS-framework locum contracts. For those still operating through a personal service company, the status of each engagement needs to be reviewed against the current working arrangements.

Annual allowance tapering and the NHS pension

Locum doctors with higher incomes are subject to the tapered annual allowance, which bites only where threshold income exceeds £200,000 and adjusted income exceeds £260,000, and then cuts the £60,000 annual allowance by £1 for every £2 of adjusted income above £260,000, reaching the £10,000 floor only at £360,000 of adjusted income. This interacts directly with NHS pension accrual. An annual allowance charge can arise from NHS pension growth alone. We model this carefully, including carry-forward from previous years.

Multiple income streams and self assessment complexity

Doctors working across NHS employed, NHS locum and private practice income streams have some of the most complex self assessment positions in the UK. The interaction between PAYE earnings, NHS pension, PSC dividends and private practice income requires careful planning and accurate filing to avoid both under-declaration and overpayment.

PSC versus umbrella for locum work

For locum doctors still operating through a PSC, the comparative analysis against umbrella or direct PAYE must account for the NHS pension implications, not just headline take-home. The pension is often the dominant factor at consultant-level incomes, and the choice of engagement structure affects annual allowance charges significantly.

How we help

What we do for NHS locum doctors.

Integrated income and pension planning

We model the full picture (NHS employed income, locum income, pension accrual, PSC dividends and private practice) and plan the most efficient structure. For doctors, this is not separable: the parts interact in ways that only become visible when you model them together.

Annual allowance management

We track your pension annual allowance position each tax year, model whether carry-forward from previous years is available, and set out how to manage pension contributions to avoid unnecessary annual allowance charges.

Self assessment for doctors

Accurate, complete self assessment returns that account for all income sources, including NHS pension annual allowance charges, dividend income and private practice receipts. Filed on time with full records retained.

Questions about NHS locum doctors

Can I still use a limited company for NHS locum work?
It depends on the nature of the engagement and the trust's determination. Some NHS locum arrangements remain outside IR35, particularly where the doctor has genuine substitution rights, works across multiple trusts, and is not integrated into the trust's management structure. But the off-payroll rules have applied to NHS trusts since 2017, so the trust makes the determination. A specialist can review your specific arrangements.
I have an annual allowance charge. Is this normal?
Annual allowance charges have affected many NHS consultants in recent years, particularly those whose pension growth exceeded the tapered allowance. HMRC's Scheme Pays mechanism allows the charge to be paid from the pension itself rather than out of pocket, but it reduces the eventual pension entitlement. We model the charge and the Scheme Pays election each year so you make an informed decision.

Free call

Talk to a contractor specialist about NHS locum doctors

Book a free call. We will talk through your IR35 position, your structure and whether there is anything worth changing. No hard sell, no obligation.

Contractor work only, not a general practice sideline, so a contractor specialist reviews your enquiry. If you would rather write to us first, use the contact form.

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