This page is designed to help Locations crew understand why different roles within the department can be treated differently for tax purposes. HMRC do not look at job titles alone. They look at what the role actually involves. Factors such as the level of responsibility, decision making authority, autonomy in delivering the work, financial risk, and whether the individual is operating as an independent business all influence how a role may be viewed for tax.
In Locations, responsibilities can vary significantly between grades and even between productions. The way a role functions in practice is what matters. The aim of this page is to help you understand how HMRC approach these assessments, why certain roles are commonly treated in particular ways, and how to ensure your status reflects the reality of what you are doing.
Getting Your Tax Status Right
Ways you can be engaged:
Self Employed (Schedule D)
Often referred to as sole trader.
You:
• Invoice production directly in your own name
• Are responsible for your own Income Tax and National Insurance
• Submit a self assessment tax return
• Do not receive statutory employment rights
• Carry your own financial risk
PAYE (Employee)
You:
• Are paid through payroll
• Have tax and National Insurance deducted at source
• Receive statutory employment protections
• Do not invoice production
• Do not manage your own tax position for that job
Limited Company (Personal Service Company)
You:
• Invoice through your limited company
• Are responsible for corporation tax, VAT if registered, and company administration
• May pay yourself via salary and or dividends
• Must consider IR35 rules
• Take on administrative and financial responsibili
What HMRC ESM4115 is really saying, and why Appendix 1 exists
HMRC created ESM4115 because film and TV has a high turnover of freelance crew, and there are a number of behind the camera roles where HMRC and the industry have agreed that self employed status is often appropriate, as long as the role meets the specific criteria set out in Appendix 1.
Appendix 1 is there to give the industry a practical guide. HMRC describe it as a handy reference so that, where the conditions are met, those roles can be accepted as self employed for tax and attention can be focused on the less straightforward cases. The list has also been refreshed over time to reflect modern roles and working practices, with industry input, including Bectu and even this branch.
What this means for you is that you should not just look for your job title on the list. You should look at the criteria that sit alongside each role. If you read a role description and think, a lot of that sounds like how I actually work on this job, it is worth checking whether Schedule D style self employed treatment might be correct for that engagement, or at least worth discussing before you sign.
It is also worth remembering that the list is not exhaustive. Being on Appendix 1 does not automatically mean someone must be treated as self employed, and being off Appendix 1 does not automatically mean someone must be PAYE. Status is assessed individually, based on what the worker is actually doing on that specific production and how the working relationship operates in practice.
In reality, it does not always feel like this on productions. Appendix 1 is sometimes treated as if it is the only factor, or used as a tick box exercise to justify a default approach to contracting. That can lead to people being told there is no choice, or that their status is fixed purely by job title. Where possible, decisions should reflect the real working arrangement, and crew should feel able to ask for clarity on how a determination has been reached and what it is based on.
Location Roles included in Appendix 1:
Location Manager (& supervisor)
Location Scout
Unit Manager
Assistant Location Manager (As of Oct 2025)
Location Coordinator (As of Oct 2025)
If your role is listed in Appendix 1, it is a strong starting point for self employed treatment, provided your working practices match the criteria. If production or payroll are relying on Appendix 1 as a blanket rule, or using it to shut down any discussion, you are entitled to ask what the decision is based on and to request that it reflects the reality of what you are doing on that job. If there is any doubt, ask for the reasoning in writing and refer to the IR35 and CEST section below for the practical steps you can take.
Need a hand on a specific job
If you are unsure how Appendix 1, CEST, IR35, or Schedule D might apply to your current contract, reach out to the branch. We cannot give personal tax advice, but we can help you sense check the language being used, point you to the relevant HMRC guidance, and help you frame the questions you should be asking production so you can get clarity before you sign.
The CEST Tool
CEST is HMRC’s online status checker. It is meant to help decide whether a specific engagement looks more like employment or genuine freelance work for tax purposes. Productions and payroll companies sometimes use it as part of their decision making, and you can run it yourself as well.
The main thing to understand is that CEST is only as reliable as the information put into it. If the person completing it does not properly understand your role, or if they answer based on a generic production policy rather than how the job will actually operate, the result can be skewed. This is why crew sometimes see CEST outcomes that feel disconnected from reality.
If a production relies on CEST, it is reasonable to ask who completed it and what assumptions were used, especially around control, supervision, and whether you are expected to deliver the work independently or under close direction. If you believe the inputs are wrong, you can run CEST yourself using accurate information and compare the results. Differences usually come down to one or two key answers, and that gives you a practical, calm way to challenge the outcome before you sign.
Lorimer Letter
What it is
A Lorimer Letter, sometimes called an LP10 letter, is an HMRC authority letter that helps certain film and TV freelancers be paid without PAYE tax being deducted at source on short engagements, because HMRC accept they are operating on a genuinely self employed basis.
Where it applies
It is mainly relevant if you want to be engaged as a self employed individual (Schedule D, not through a limited company) and productions or payroll are pushing to put you on PAYE by default. It is used most often for short term, project based work across multiple engagers, which is common in our industry.
It is not the right tool for every situation, and it is not a substitute for getting your employment status right. Think of it as something that can support self employed treatment where your working pattern clearly looks like freelance work across multiple production companies.
Who can usually get one
The widely used industry rule of thumb referenced is that you should be able to show you have worked for at least 10 separate engagers, and for less than 10 days for each engager, in the previous 12 months. It is ideal for someone who might be marshalling or assisting across many different projects, only doing a day here and there.
How to get it
Lorimer and LP10 letters are handled through HMRC’s Film and TV Production Unit, often referred to in the industry as SO733. If you are applying, this is the right place to start, as they can confirm the current process and tell you exactly what evidence they expect to see for your working pattern.
A practical way to approach it:
Pull together evidence of your last 12 months of engagements, including engager names and dates, showing the short engagement pattern.
Contact HMRC Film and TV Production Unit SO733 and ask for the Lorimer or LP10 application process and any forms they require.
Once issued, keep a copy and provide it to production or payroll when discussing how you should be paid on relevant engagements