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HMRC internal manual

Employment Status Manual

Particular occupations: doctors

Doctors may receive income from a variety of different sources. The guidance which follows is primarily concerned with income which doctors receive for work for Health Authorities or National Health Service (NHS) Trusts. It should however be remembered that even doctors working full-time for Health Authorities or NHS Trusts may receive some fees assessable as trading income, and liable to Class 2/4 NICs, such as fees for completing the special death certificate necessary before a body may be cremated.

Full-time or part-time appointments within the NHS are generally offices or employments. The emoluments/earnings from such appointments are taxable as employment income, (see Mitchell and Edon v Ross 40TC11), and are subject to Class 1 NICs.

For tax purposes only, any emoluments/earnings from part-time offices or employments may in practice be treated as professional receipts chargeable as trading income where EIM03002 applies and where

  • the doctor so wishes, and
  • they are small in comparison to the other professional receipts assessable as trading income.