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IR35 basics for locums

Updated Sun, 14 Jun 2026 1 min read

IR35 (the off-payroll working rules) is tax legislation about whether someone working through an intermediary — such as their own limited company — is really acting like an employee. It exists to stop "disguised employment".

Does it apply to me?#

  • If you work as a sole trader invoicing pharmacies directly, IR35 in its off-payroll form generally isn't the mechanism that applies — but your employment status for tax can still be questioned by HMRC.
  • If you work through your own limited company, the off-payroll rules can be relevant, and responsibility for assessing status may sit with the engager.

Why it matters#

Getting status wrong can lead to unexpected tax and National Insurance bills. The rules are nuanced and depend on how you actually work — not just the label on a contract.

Where to get proper advice#

This is a simplified overview, not tax advice. IR35 is genuinely complex — speak to an accountant who knows locum/healthcare work and check the current HMRC guidance before relying on any position.

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General information only — not financial, tax, or legal advice. Always check official sources (GOV.UK, HMRC, GPhC) and consult a qualified professional about your own situation.