VAT For Locum Doctors : The Rapid Sequence Case

A recent tax case has clarified the VAT treatment of services provided by self employed locums.

In circumstances where a self employed locum provides their services to the client through an agency, and the client is legally responsible for providing health care to the final patient, the services of the locum are subject to VAT.

For example, the services of locum doctors working in an NHS hospital engaged through an agency will be subject to VAT.

Locums should note that this will be the case whether they are self employed or trade through an umbrella company or a personal service company.


Although the services of the locum may be subject to VAT, the doctor will not need to register for, charge or account for VAT until the locum’s services within a 12 month period exceed the VAT registration threshold, currently £82,000.


  • We can review the services you provide to establish if you need to register for VAT.
  • If you need to register for VAT we can help you with this process.
  • We can help complete VAT returns and payments.
  • We can advise you in relation to tax efficient VAT schemes.