EIM61012 - Tax treatment of doctors: pre-registration house officers: living accommodation

Doctors in training grades may be considered to be in a different type of employment from doctors employed in career grades. In particular, although hospital doctors may be employed in one of three training grades – pre-registration house officer (PRHO), senior house officer and specialist registrar – employment as a PRHO is clearly distinguishable because a PRHO is still a student. Although a PRHO uses the title of Doctor, this title is provisional on the satisfactory completion of a year of clinical training.

As a PRHO contractually must be provided with living accommodation during this year of clinical training, HMRC accepts that conditions specified at section 99(2) ITEPA 2003 are satisfied (see EIM11346). Therefore a PRHO is exempt from charge to tax under Part 3 Chapter 5 ITEPA 2003 in respect of the provision of living accommodation.