Hong Kong Locum Doctor & Nurse Tax — Expert Advisory

The classification depends on the actual working relationship. A locum doctor who works independently — sets their own hours, works for multiple clinics, provides their own equipment, and bears financial risk — is likely self-employed and should file profits tax returns. A locum who works fixed hours at one clinic, under direction, with the clinic's equipment, and with ongoing mutual obligation, is more likely an employee. In practice, many locum arrangements fall in a grey area, and the IRD applies the multi-factor control, integration, and economic reality tests.

Self-employed locums can deduct: professional indemnity insurance; annual practising certificate fees (Medical Council of Hong Kong); professional membership fees (HKMA, HKCOS, etc.); CPD course registration fees; medical reference books and journals; medical bag contents and basic instruments; clinic visit travel costs (public transport or vehicle mileage); and home office expenses if used for medical records and administration. Clinical consumables provided by the clinic are the clinic's expense. The expense must be wholly and exclusively for the locum practice.

Self-employed locum doctors carrying on a profession in Hong Kong are required to register their business with the Business Registration Office within 1 month of commencement. The annual business registration fee is modest (currently HKD 2,000). Failure to register carries penalties. The business registration is separate from the Medical Council practising certificate — both are required for a self-employed locum practice.

If a nursing agency places a nurse at hospitals and deducts commission before paying the nurse — the question is whether the nurse is an employee of the agency or an independent contractor. If the nurse is an employee of the agency, the agency reports gross salary on IR56B and the commission is the agency's cost, not the nurse's deduction. If the nurse is a self-employed person operating through the agency as agent, the full gross fee is the nurse's income and the agency commission is a deductible expense.

Yes. Self-employed persons who carry on a business, trade, or profession in HK are required to enrol in an MPF scheme as self-employed persons. They must contribute a mandatory amount of 5% of their relevant income (between HKD 7,100-HKD 30,000 per month in 2024 terms), with a maximum contribution of HKD 1,500/month. Self-employed MPF contributions are generally deductible against assessable profits for profits tax purposes.