Tax Management
September 16, 2026
The Tax Benefit for Medical Clinics from the Perspective of Tax Avoidance
Pedro Guilherme de Moraes Maestrelli; Raissa Alvares de Matos Miranda
DOI: 10.22167/2675-6528-202602308
Article derived from a Final Course Work (TCC), with content based on the student’s original work and adapted to the editorial format of the Revista E&S with the support of the ResumeAI tool, an artificial intelligence solution developed by the Pecege Institute for textual synthesis and organization.
Abstract
The growing national tax burden has driven companies to adopt strategies to mitigate its impacts. In this context, the tax benefit for a medical clinic opting for the presumed profit regime was analyzed, located in Ponta Grossa, Paraná, from the perspective of tax avoidance, after its corporate reorganization. The objective was to verify the legal viability of reducing the tax base for Corporate Income Tax (IRPJ) and the Social Contribution on Net Profit (CSLL) to 8% and 12%, respectively, for activities considered hospital-related. A qualitative, descriptive, and exploratory case study was conducted, with documentary analysis of articles of association, invoices, accounting records, and payment slips from Clínica Beta, confronting them with legislation and jurisprudence. The data were supplemented by doctrinal review and judgments from CARF and STJ. It was found that the inclusion of a non-medical partner in the partnership met the requirements for enjoying the tax benefit, provided that the business purpose of the change was maintained and documentary evidence, such as a shareholders’ agreement, was built. The application of the measure resulted in tax relief exceeding 70% in IRPJ and CSLL payments. It was concluded that the tax avoidance strategy, when based on legal and regulatory compliance, provides legal certainty and tax optimization, mitigating contingency risks and promoting business sustainability.
Keywords: Analysis; Economy; Planning; Taxation.
1. Introduction
The national economic scenario has been marked by frequent increases in the tax burden, which drives several companies to seek strategies to mitigate their impacts. Such measures aim to optimize profit margins, improve cash flow, and adjust market prices, ensuring business sustainability in a challenging fiscal environment.
In this context, tax planning emerges as an essential technique of preventive organization, whose objective is to promote tax savings. This practice must be carried out with strict observance of legality and compliance with current legislation, without the actions taken generating adverse consequences (Tôrres, 2001). The freedom of choice and action in economic activity, inherent to tax planning, finds legal support in the Federal Constitution and in Law No. 6.404/76, which requires the administrator to exercise the necessary diligence for the proper conduct of business (Chaves, 2017).
Legal doctrine, especially from the interpretation of articles 149 and 116 of the National Tax Code (1966), distinguishes tax planning into three main categories: tax avoidance, tax evasion, and tax fraud. Tax avoidance refers to a set of lawful actions that taxpayers can employ to restructure their business models, avoiding or deferring the incidence of taxes and generating savings, without violating legislation (Tôrres, 2001). On the other hand, tax evasion also involves a planned restructuring for tax savings, but the acts are devoid of business purpose, serving solely to avoid the taxable event (Tôrres, 2001). Historically, Dória (1977) and Xavier (1978) considered tax evasion as a form of tax avoidance, as long as the acts were legally perfect and in compliance with the law. Tax fraud, in turn, is characterized by fraudulent conduct, whether by omission or commission, in which the taxpayer evades their duty to pay taxes (Tôrres, 2001). Nishioka (2010) emphasizes that tax evasion still lacks clear regulation, while the National Tax Code already provides for combating tax fraud.
Legal certainty in tax planning has been built over decades of discussion, involving administrative and judicial debates, as well as doctrinal improvements, with a focus on the relationship between cause and motive in legal transactions. For Pereira (1998), verifying the cause requires excluding motives, isolating an autonomous legal reason that represents the economic and social purpose guaranteed by law, transcending the mere formalization of the act itself. This distinction is crucial for determining the lawfulness of the strategies adopted.
In this context, a normative gap in the concept of hospital services, essential for the enjoyment of tax benefits, requires recourse to jurisprudential understanding. The central problem lies in understanding whether the mere inclusion of a non-medical partner in the corporate structure of a medical clinic, opting for the presumed profit regime, is sufficient to characterize the economic activity as business-related. Such characterization is fundamental to consolidate the use of the tax benefit of reducing the tax base for Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL), according to article 15, §1º, item III, letter “a”, of Law nº 9.249/95. The practical relevance of the topic lies in the healthcare sector’s need to mitigate the impacts of high tax burden, optimizing cash flow and enabling greater investments, without disregarding tax governance. Academically, the study contributes to the debate on the conceptual boundaries between tax avoidance and tax evasion, especially in the reinterpretation of business purpose in corporate reorganizations. Given the foregoing, this research aims to understand whether the mere inclusion of a non-medical partner in the corporate structure of a presumed profit medical clinic is sufficient to characterize the economic activity as business-related and, thus, consolidate the use of the tax benefit provided by art. 15, §1º, item III, letter “a” of Law nº 9.249/95, from the perspective of tax avoidance practices.
2. Material and Methods
The research is characterized as a qualitative case study, of a descriptive and exploratory nature, based on bibliographic and documentary analysis procedures (Gil, 2002), using the case study as a technical procedure (Yin, 2015).
The central objective was to verify the legal feasibility of reducing the calculation basis to 8% for Corporate Income Tax (IRPJ) and 12% for the Social Contribution on Net Profit (CSLL), from the perspective of hospital activities.
For the analysis, a for-profit medical clinic was used, located in Ponta Grossa, Paraná, which, in 2024, altered its corporate structure to include a non-medical professional in its partner base, aiming to comply with the tax benefit requirement.
Data collection occurred after signing a term of authorization and commitment for the use of information, ensuring institutional anonymity through the codename Beta Clinic.
The primary sources used included the original and amended social contract, National Legal Entity Registry (CNPJ) card, service invoices (period Sep./2023-Oct./2023), Fiscal Record of the fiscal year 2023 (ECF), and proof of payment (DARF) for Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL).
To ensure transparency, the primary sources collected and their analytical objectives are presented in Table 1.
Table 1. Analyzed documents
| Analyzed document | Analytical objective |
|---|---|
| Social Contract | Analyze the corporate transition and the adequacy of the corporate purpose to the requirements of hospital activity. |
| CNPJ Card | Validate the regularity of registration and the compatibility of activity codes (CNAE). |
| Service Invoices [NFS-e] | Verify the nature of the services provided for specific tax classification purposes. |
| ECF | Evaluate accounting consistency in the calculation of presumed calculation bases. |
| DARF | Confirm the effective collection of taxes at the claimed presumptive rates. |
Source: Original research data.
Complementarily, the analysis considered constructions from the doctrine, tax legislation, rulings from the Administrative Council for Tax Appeals (CARF), decisions issued by appellate judges in similar cases at the Regional Federal Court of the 4th Region (TRF-4) and the Superior Court of Justice (STJ).
The treatment of information was based on systematic documentary analysis (Bardin, 2011) and data triangulation, confronting the operational reality of Clínica Beta with doctrinal and jurisprudential constructions. This procedure allowed us to validate whether the corporate change promoted by the company is sufficient to comply with tax avoidance rules and take advantage of the tax base reduction benefit for IRPJ and CSLL for medical clinics under the presumed profit regime that carry out hospital activities.
Finally, the Research Ethics Code was strictly observed according to Resolution CNS n. 466/2012, noting that, as it is a single case study, the conclusions are limited to the analyzed unit, not encompassing quantified economic impacts.
3. Results and Discussion
The analysis of the present study began with the characterization of Clínica Beta in its original configuration, operating as a sole-member limited liability company with a single physician partner, duly registered with the Regional Council of Medicine (CRM). In this scenario, the clinic was framed within the presumed profit regime and was subject to the presumed calculation base of 32% on gross revenue for the collection of Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL), according to Law nº 9.249/1995.
Regarding the Service Tax (ISS), Clínica Beta issued invoices with service code 4.03 (hospitals, clinics, laboratories, sanatoriums, asylums, health clinics, emergency rooms, outpatient clinics, and the like) for surgeries, and with code 4.01 (medicine and biomedicine) for consultations. The distinction between procedure and consultation in the invoices is an essential requirement for the reduction of the tax base, according to Complementary Law nº 116/03 and current jurisprudence.
To demonstrate the adopted practice, Table 2 presents the detailed description of the invoices issued between September and October 2023.
Table 2. Descriptive of the invoices
| Tax Invoice | Emission | Service Code | Value |
|---|---|---|---|
| 4 | 14/09/2023 | 403 | 3.900,00 |
| 5 | 14/09/2023 | 403 | 24.650,00 |
| 6 | 14/09/2023 | 403 | 10.750,00 |
| 7 | 14/09/2023 | 403 | 5.100,00 |
| 8 | 14/09/2023 | 403 | 29.100,00 |
| 9 | 14/09/2023 | 403 | 14.680,00 |
| 10 | 14/09/2023 | 403 | 6.850,00 |
| 12 | 14/09/2023 | 403 | 6.000,00 |
| 13 | 18/09/2023 | 403 | 10.440,00 |
| 14 | 19/09/2023 | 403 | 14.500,00 |
| 15 | 20/09/2023 | 403 | 12.840,00 |
| 16 | 21/09/2023 | 403 | 23.520,00 |
| 17 | 21/09/2023 | 403 | 14.400,00 |
| 18 | 21/09/2023 | 403 | 12.840,00 |
| 20 | 21/09/2023 | 403 | 5.400,00 |
| 28 | 03/10/2023 | 403 | 1.000,00 |
| 34 | 06/10/2023 | 403 | 1.200,00 |
| 35 | 11/10/2023 | 403 | 15.000,00 |
| 37 | 16/10/2023 | 403 | 9.820,00 |
| 38 | 17/10/2023 | 403 | 10.300,00 |
| 39 | 18/10/2023 | 403 | 5.000,00 |
| 40 | 18/10/2023 | 403 | 1.500,00 |
| 42 | 23/10/2023 | 403 | 15.300,00 |
| 44 | 23/10/2023 | 403 | 21.600,00 |
| 45 | 25/10/2023 | 403 | 15.000,00 |
| 46 | 26/10/2023 | 403 | 1.000,00 |
| 47 | 26/10/2023 | 403 | 10.750,00 |
Source: Original research results.
It was observed that Clínica Beta, according to the provided invoices, had revenue primarily from services with code 4.03, reserving subitem 4.01 exclusively for occasional medical consultations. The clinic focuses on specialized surgical procedures and does not perform internal examinations. The descriptions on the invoices specify surgical procedures such as removal of small skin tumors, blepharoplasty, bichectomy, liposuction, rhinoplasty, mammoplasty, and abdominoplasty, diverging from outpatient care.
The adequacy of the company’s accounting and tax records is essential to reflect the facts of economic activity. The adoption of reduced rates of 8% for IRPJ and 12% for CSLL is supported by article 15, §1º, item III, letter “a”, of Law nº 9.249/1995, which grants the benefit to services considered equivalent to hospital activities.
To quantify the efficiency of the proposed planning, Table 3 demonstrates the tax burden incurred without the enjoyment of the tax benefit.
Table 3. Demonstration of taxation without the application of the tax benefit.
| Nature | Scenario “regular taxation” |
|---|---|
| Gross Revenue | R$ 302,440.00 |
| IRPJ Presumption (32%) | R$ 96,780.80 |
| CSLL Presumption (12%) | R$ 36,292.80 |
| IRPJ to pay (15%) | R$ 14,517.12 |
| Additional IRPJ to pay (10%) | R$ 3,678.08 |
| CSLL payable (9%) | R$ 3,266.35 |
| Total to pay | R$ 21,461.55 |
Source: Original research results.
Subsequently, Table 4 details the amounts due with the application of reduced rates, highlighting the tax savings generated by hospital equalization.
Table 4. Statement of taxation with the application of the tax benefit.
| Nature | Scenario “hospital equalization” |
|---|---|
| Gross Revenue | R$ 302,440.00 |
| IRPJ Presumption (8%) | R$ 24,195.20 |
| CSLL Presumption (12%) | R$ 36,292.80 |
| IRPJ to pay (15%) | R$ 3,629.28 |
| Additional IRPJ to pay (10%) | |
| CSLL payable (9%) | R$ 3,266.35 |
| Total to pay | R$ 6,895.63 |
Source: Original research results.
The comparative analysis of Tables 3 and 4 indicated that the application of the hospital equalization benefit would result in a tax reduction of R$ 14,565.92 in a period of just over one month for Clínica Beta. This amount represents a tax optimization, allowing the funds allocated to taxes to be directed towards the clinic’s structure.
For the enjoyment of the benefit, it is necessary to comply with the requirements of the legislation, including the normative gap in the concept of hospital services, which requires resorting to jurisprudential understanding. The Superior Court of Justice (STJ), in Theme 214 (2009), established that the tax benefit for hospital services is objective, focused on the services provided and not on the taxpayer. The Court delimited that hospital services are those linked to the activities developed by hospitals, aimed at health promotion, and that the institution has costs differentiated from simple medical care, without the hospitalization of patients being a mandatory requirement.
Additionally, Law nº 11.727/08 amended subparagraph “a” of the legislation, establishing three requirements for the enjoyment of the benefit: i) being included in the presumed profit tax regime; ii) being classified as a business company; and iii) complying with the regulations of the National Health Surveillance Agency (ANVISA).
The documentary examination of Clínica Beta confirmed that the company opted for the presumed profit regime and that the National State Vigilance permit attests to its compliance with ANVISA regulations. The central point of the investigated planning focused on the classification of the clinic as a “business company”. Originally, Clínica Beta, although registered with the Commercial Registry, was linked to the intellectual and personal activity of the sole medical partner, fitting the profile of a simple society, according to the Civil Code of 2002. The 2024 corporate change, which included a non-medical partner, highlighted the transition to a structured economic organization.
This strategy aligns with the understanding consolidated by the First Panel of the TRF-4 (2022), which requires proof of its own structure, such as equipment and staff, for the taxpayer to enjoy the benefit. The magistrates also indicate that even a limited liability company composed of regulated professionals can be considered an intellectual professional company, not a business, if there are no elements of a business. In another case, the TRF of the 4th Region (2023) exemplified indications of non-business characterization, such as the absence of its own headquarters. The inclusion of a non-medical partner, therefore, is characterized as an essential requirement for the application of reduced rates of 8% for IRPJ and 12% for CSLL, breaking with the presumption of purely intellectual activity.
For comparison purposes, Table 5 presents the projection of the IRPJ tax burden under the general rule of 32%, reflecting the scenario without tax planning.
Table 5. Calculation of IRPJ taxed by the presumption of 32%.
| Period | Gross surgical revenue | % | Gross revenue query | % | Assumed base | IRPJ | Additional IRPJ | Reporting |
|---|---|---|---|---|---|---|---|---|
| 1st Qtr. | 320.000,00 | 32 | 80.000,00 | 32 | 128.000,00 | 19.200,00 | 10.800,00 | 30.000,00 |
| 2nd Qtr. | 320.000,00 | 32 | 80.000,00 | 32 | 128.000,00 | 19.200,00 | 10.800,00 | 30.000,00 |
| 3rd Qtr. | 320.000,00 | 32 | 80.000,00 | 32 | 128.000,00 | 19.200,00 | 10.800,00 | 30.000,00 |
| 4th Qtr. | 320.000,00 | 32 | 80.000,00 | 32 | 128.000,00 | 19.200,00 | 10.800,00 | 30.000,00 |
| TOTALS | 120.000,00 |
Source: Original research results.
In contrast, Table 6 shows the impact of applying the reduced rate of 8% on surgery revenues, maintaining the 32% only for consultations, evidencing the income tax relief.
Table 6. Calculation of IRPJ taxed by the presumption of 8% and 32%.
| Period | Gross surgical revenue | % | Gross revenue query | % | Assumed base | IRPJ | Additional IRPJ | Reporting |
|---|---|---|---|---|---|---|---|---|
| 1st Qtr. | 320.000,00 | 8 | 80.000,00 | 32 | 51.200,00 | 7.680,00 | 3.120,00 | 10.800,00 |
| 2nd Qtr. | 320.000,00 | 8 | 80.000,00 | 32 | 51.200,00 | 7.680,00 | 3.120,00 | 10.800,00 |
| 3rd Qtr. | 320.000,00 | 8 | 80.000,00 | 32 | 51.200,00 | 7.680,00 | 3.120,00 | 10.800,00 |
| 4th Qtr. | 320.000,00 | 8 | 80.000,00 | 32 | 51.200,00 | 7.680,00 | 3.120,00 | 10.800,00 |
| TOTALS | 43.200,00 |
Source: original research data.
It was verified that the quarterly IRPJ surcharge, which was R$ 10,800.00 in the scenario without the benefit (Table 5), decreased to R$ 3,120.00 after the segregation of revenues and reduction of the tax base (Table 6), since the presumed tax base is also used for the 10% IRPJ surcharge.
Following the same comparative logic for Social Contribution, Table 7 shows the collection of CSLL calculated on the base of full presumption (32%).
Table 7. Calculation of CSLL taxed by the presumption of 32%.
| Period | Gross surgical revenue | % | Gross revenue query | % | Assumed base | CSLL | Reporting |
|---|---|---|---|---|---|---|---|
| 1st Qtr. | 320.000,00 | 32 | 80.000,00 | 32 | 128.000,00 | 11.520,00 | 11.520,00 |
| 2nd Qtr. | 320.000,00 | 32 | 80.000,00 | 32 | 128.000,00 | 11.520,00 | 11.520,00 |
| 3rd Qtr. | 320.000,00 | 32 | 80.000,00 | 32 | 128.000,00 | 11.520,00 | 11.520,00 |
| 4th Qtr. | 320.000,00 | 32 | 80.000,00 | 32 | 128.000,00 | 11.520,00 | 11.520,00 |
| TOTALS | 46.080,00 |
Source: original research data.
Finally, Table 8 illustrates the optimized scenario for CSLL, with the calculation base reduced to 12% for services equated to hospital services, as per the proposed planning.
Table 8. Calculation of CSLL taxed by the presumption of 12% and 32%.
| Period | Gross surgical revenue | % | Gross revenue query | % | Assumed base | CSLL | Reporting |
|---|---|---|---|---|---|---|---|
| 1st Qtr. | 320.000,00 | 12% | 80.000,00 | 32% | 64.000,00 | 5.760,00 | 5.760,00 |
| 2nd Qtr. | 320.000,00 | 12% | 80.000,00 | 32% | 64.000,00 | 5.760,00 | 5.760,00 |
| 3rd Qtr. | 320.000,00 | 12% | 80.000,00 | 32% | 64.000,00 | 5.760,00 | 5.760,00 |
| 4th Qtr. | 320.000,00 | 12% | 80.000,00 | 32% | 64.000,00 | 5.760,00 | 5.760,00 |
| TOTALS | 23.040,00 |
Source: Original research results.
The examination of the data presented in Tables 5, 6, 7, and 8 allows for the quantification of the tax efficiency of applying the hospital equivalence in Clínica Beta. In the scenario prior to the adjustment, the total tax burden projected for the year 2023, considering IRPJ and CSLL, amounted to R$ 166,080.00. With the application of the reduced presumption of 8% and 12%, respectively, on surgical procedure revenues, the tax calculation was reduced to R$ 66,240.00. This transition generated tax savings of R$ 99,840.00 in the period, representing a reduction of 60.11% in fiscal disbursement related solely to these federal taxes.
The materialization of planning, with the inclusion of a non-medical partner in the company structure, can be considered tax avoidance if there is no business purpose. To ensure legal certainty and compliance, it is essential to understand the role of this new partner in the business activity. Recent rulings by the CARF (2024, 2025) highlight the absence of business purpose in corporate transactions that produce tax effects, such as the depletion of share capital without any business reason other than the tax impact, or when no practical change occurs, only a fictitious one.
To address this gap and promote tax avoidance, the formalization of a parasocial agreement, such as a shareholders’ agreement, is proposed. Vergueiro (2010) explains that the articles of association can be rigid, and a parasocial agreement can detail the functions, remuneration, and practical responsibilities of those involved. The Law of S.A.s (1976), in its article 118, codified this modality, also applicable to limited liability companies, provided that the Civil Code is respected and it is filed with the Commercial Registry. The suggestion is that this agreement outlines the functions and responsibilities of the partner who joined the company, providing greater legal certainty and corporate and tax compliance. Other documents, such as service provision agreements by the new partner or participation in events representing the clinic, can complement the proof of business purpose.
With the formalization of the shareholders’ agreement, the medical clinic will be able to fully benefit from the reduced tax base for IRPJ and CSLL. The requirements are: i) presumed profit regime (verified by the ECF); ii) medical activity equivalent to hospital services (verified by invoices); iii) compliance with ANVISA regulations; and iv) organization as a business entity, with the formalization of the shareholders’ agreement for the role of the new non-medical partner. The correct application of legislation and the formalization of the shareholders’ agreement can result in a 74.42% reduction in the company’s IRPJ and CSLL payments, representing significant prospective savings, improving investments, profit margins, and tax efficiency.
4. Conclusion
This study was dedicated to verifying the legal feasibility of reducing the calculation basis for Corporate Income Tax (IRPJ) and the Social Contribution on Net Profit (CSLL) to 8% and 12%, respectively, for a medical clinic opting for the presumed profit regime, after its corporate reorganization, from the perspective of tax avoidance. The analysis of Clínica Beta revealed that the inclusion of a non-medical partner in the partnership, in compliance with ANVISA regulations and the presumed profit regime, allowed for equalization with hospital services. It was found that this strategy resulted in tax relief exceeding 70% in IRPJ and CSLL payments, representing significant savings. To ensure legal certainty and the business purpose of the change, the formalization of a shareholders’ agreement, detailing the new partner’s functions, proved essential to characterize the action as tax avoidance. The main contribution lies in offering a practical framework for medical clinics to structure tax planning with a high degree of security, mitigating risks of tax contingencies and promoting business sustainability, in addition to enriching the academic debate on the boundaries between tax avoidance and tax evasion.
However, it is necessary to recognize the inherent limitations of the methodological design. Because it is a single case study, strictly focused on the operational and accounting reality of Clínica Beta, the conclusions and quantified economic impacts do not automatically generalize to other organizations in the sector, nor do they contemplate conjunctural variables that could influence the tax burden in different specialties or more complex corporate structures. Tax interpretation, by its nature, has a degree of subjectivity that can always generate questions from the federal tax authorities. For future studies, it is suggested to conduct broader empirical research that assesses the effectiveness of such parasocial agreements in different contexts and the analysis of more complex corporate structures, as well as the projection of economic impacts for a larger universe of clinics.
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Article originating from the Course Conclusion Work of the Specialization in Tax Management of the MBA USP/Esalq
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