Article
November 10, 2025
Tax planning: tax incentives for health cooperatives
Authors: Natália Mucida Zanini and Beatriz da Silva Pereira
DOI: 10.22167/2675-6528-2024073
E&S 2025, 6: e2024073
Modern cooperativism emerged in the 19th century, during the Industrial Revolution, as an organizational alternative aimed at improving working conditions and promoting the social and economic development of workers[1]. In Brazil, the movement consolidated at the end of this period and expanded into various sectors, with emphasis on the health area, one of the most representative branches. This organizational model reconciles economic and social interests, promoting cooperation and collective development[2].
Currently, cooperativism represents an expressive force in the Brazilian economy, with millions of associates and thousands of cooperatives. The health segment, in particular, plays a strategic role in providing services to the population and in generating jobs for medical professionals[3].
From a legal and accounting perspective, cooperatives have a unique nature: they do not aim to obtain their own profit, but to provide services for the benefit of their members. Brazilian legislation recognizes this characteristic and distinguishes between acts practiced among members and the cooperative — the so-called cooperative acts — and operations carried out with third parties, called non-cooperative acts[4]. This differentiation is essential for tax treatment, as only non-cooperative acts are subject to taxation.
In this scenario, tax planning is configured as a relevant tool for the efficient management of health cooperatives. Among the available instruments, tax incentives provided for in the Income Tax (IR) legislation stand out, which allow deductions in specific situations, especially when linked to initiatives of social interest, such as donations to civil society organizations[5]. These mechanisms contribute to the reduction of the tax burden and reinforce the social role of cooperatives.
Therefore, this study aims to analyze the applicability of tax incentives within health cooperatives and evaluate their effectiveness as a tax planning strategy. The work encompasses the impacts of these practices on the tax burden and the sector’s sustainability, as well as offering subsidies to managers and researchers interested in the interface between taxation, cooperativism, and social responsibility.
From a legal perspective, the cooperative constitutes a form of collective organization that brings together individuals around common objectives, possesses its own legal personality and a civil nature distinct from business partnerships[6]. Its establishment requires a minimum number of participants and its central purpose is the provision of services to members. Cooperative activity is based on joint economic participation, market presence, and the defense of shared interests, as well as being a model that integrates social organization and economic development[2].
Brazilian cooperativism has registered expressive growth. Recent data indicate continuous growth in the number of cooperatives and members, which demonstrates the relevance of the topic for economic and social sustainability[7]: in 2022, the country counted about 18.8 million members, an increase of 10% compared to 2020, and approximately 4,880 active cooperatives, with emphasis on the services sector, especially in the field of health[2]. Health cooperatives emerged to fill gaps left by the State in the provision of services in this area, assured as a fundamental right by Law No. 8.080/1990[8,9,10].
Cooperative societies present legal peculiarities since their constitution, reflected in their mode of operation and structured according to the applicable corporate regime. According to art. 146 of the Federal Constitution, the cooperative act performed in the name of the associates receives differentiated tax treatment and is exempt from taxes on revenue or profit, such as PIS, COFINS, IRPJ, CSLL, and ISSQN, as it represents the wealth of the cooperators and not of the cooperative[11].
In contrast, non-cooperative acts — operations carried out with third parties, without connection to the cooperative’s institutional objectives and of a commercial nature — are subject to taxation, as provided for in Law No. 5.764/71 (arts. 85, 86 and 88)[4]. The current legislation does not precisely define the scope of cooperative acts, which leads to divergent interpretations regarding their coverage.
In this context, tax incentives play a strategic role in the sustainable development of cooperatives. According to Article 174, §2º, of the Federal Constitution, the State, as the regulatory agent of economic activity, exercises inspection, incentive, and planning functions, and adopts legal and regulatory measures to foster specific sectors of the economy. Based on this framework, the present study proposes to analyze the application of tax planning in health cooperatives through tax incentives and to evaluate the effectiveness of the tax burden reduction resulting from donations to Civil Society Organizations (Law 13.019/2014)[12], based on the deductions provided for in Article 13, §2º, item III, of Law No. 9.249/95[13].
Research developed in the area of health cooperatives presents distinct approaches regarding the object studied, such as, for example, antitrust practices carried out between cooperatives, with regard to the cartelization of health professionals, through their association[14]. From an accounting perspective, relevant research lines are identified concerning the composition and structuring of the Statement of Income model for health cooperatives, as operators, based on the standard chart of accounts required by the National Health Agency (ANS)[15]. However, a lack of studies focused on the tax incentives line is observed.
Given the presented context, this research seeks to contribute theoretically to the advancement of scientific production on health cooperatives, with an emphasis on the tax aspects related to accounting statements. In a practical way, the study aims to provide subsidies to members of the Executive Boards and Boards of Directors of medical cooperatives, and assists in the reorganization of operations and in reflection on fiscal issues.
Furthermore, the study incorporates a social dimension by providing information that favors the economic and sustainable development of these entities, in line with Objective 8 of the Sustainable Development Goals (SDGs) of the Institute for Applied Economic Research (IPEA), focused on decent work and economic growth, as well as promoting inclusive, sustainable growth and full and productive employment.
This work is characterized as descriptive and qualitative in approach, based on documentary analysis and interpretation of norms, theoretical concepts, and accounting practices applicable to health cooperatives[16,17]. The research used data available on public websites of medical work cooperatives, located in the regions of Triângulo Mineiro, Metropolitan Belo Horizonte, Zona da Mata, and Vale do Rio Doce, referring to the financial years of 2021.
The sample is composed of five health cooperatives of 1st and 2nd degree belonging to the medical cooperative system of the mentioned regions. The inclusion criteria were: (i) cooperatives that disclose accounting statements and information about Corporate Income Tax (IRPJ) for 2021 and (ii) availability of a complete balance sheet in public sources. Cooperatives that do not provide complete or restricted access data were excluded. The selection of the analysis units occurred intentionally, considering regional representativeness and relevance in the sector.
For data collection and organization, electronic spreadsheets (Microsoft Excel) were used, which systematize information on income statements and balance sheets. Document analysis was based on current tax legislation, Brazilian accounting standards from the Federal Accounting Council, and specialized literature on cooperativism and taxation.
Data collection occurred in three stages: (i) identification of cooperatives that met the inclusion criteria; (ii) extraction of accounting and tax information, with income statements and balance sheets for the year 2021, directly from institutional websites and transparency systems; (iii) organization and categorization of data in electronic spreadsheets, in order to relate accounting information to applicable tax regulations.
From this, the analysis was conducted qualitatively, based on the interpretation of secondary data, such as reports from independent auditors, balance sheets, and Income Statements, made available on the cooperatives’ websites, along with theoretical concepts, accounting standards, and tax legislation. This procedure made it possible to understand the acts performed by the cooperatives, identify potential tax benefits arising from their operations, and provide subsidies for operational reorganization and tax optimization. The investigation followed principles of documentary triangulation and critical interpretation, which ensures consistency, methodological rigor, and robustness in the evaluation of results[18].
The accounting and fiscal results of the analyzed medical cooperatives evidenced the relevance of the distinction between cooperative and non-cooperative acts, a decisive aspect for both the measurement of results and the use of tax incentives. As provided for in the legislation[4], only non-cooperative acts constitute a taxable base, as they represent operations carried out with third parties external to the company. However, the research indicates that, in practice, the segregation between these types of operations is not yet uniform among the analyzed cooperatives.
The data from health cooperatives A, B, C, D, and E (Tables 1 to 3) reveal a large discrepancy in the 2021 results, partly explained by management factors, portfolio claims, and beneficiary default. Only Cooperative (A) presented explicit segregation between cooperative and non-cooperative acts, in which revenue from premiums, financial investments, and related expenses are identified in each category. This practice allowed for the projection of tax incentives based on the results of non-cooperative acts (Tables 4 and 5) and reduced the amount of IR due.
In the other cooperatives, the absence of segregation compromised the calculation of the taxable base, which limited the application of the 2% deduction incentive provided for in art. 13, §2º, III, of Law No. 9.249/95[13]. This finding shows that the distinction between cooperative and non-cooperative acts is a practical condition for the effectiveness of tax planning.
Thus, the empirical results reinforce that maintaining segregated accounting records not only meets legal compliance but also increases the tax gains of medical cooperatives. Tax incentives linked to non-cooperative acts have proven viable and relevant, especially in scenarios of financial pressure in the supplementary health sector. It is concluded that the adequate classification of acts directly impacts the economic-financial sustainability of cooperatives and expands their capacity to fulfill the social function foreseen in the Constitution and specific legislation.
From tax incentives – Corporate Income Tax
Income Tax legislation grants tax incentives to legal entities taxed based on real profit that make donations to CSOs, up to the limit of 2% of operating profit. The regulatory framework for CSOs, provided for in Law No. 13.019/2014[12], authorizes them to receive donations from companies of up to 2% of their gross revenue. However, the tax incentive refers to the deduction in the calculation of Corporate Tax and the tax base for Social Contribution on Net Income, it does not imply a deduction of the taxes to be paid, as established by Law No. 9.249/95[13].
In this way, it is understood that, if the conditions provided for in art. 13, § 2º, item III of Law No. 9.249/95[13] are met, any company that calculates Income Tax based on actual profit may deduct the amount related to the donation made. Donations will be deductible in the calculation of actual profit and in the tax base of the donating company’s Social Contribution on Net Income. Due to the peculiarity of the analyzed health cooperatives, the IRPJ and CSLL are levied only on the portion of non-cooperative acts.
Thus, in a first analysis, there is a risk that the Federal Revenue Service may interpret the limitation of deductions in cooperatives in proportion to the donation made in relation to non-cooperative acts, based on the logic of the provisions of the Normative Opinion of the Coordination of the Taxation System (PN/CST) No. 73 of 1975[19]. Such an understanding could be reinforced by the fact that Law No. 9.249/95[13] provides that the deduction occurs in the calculation of real profit, and not on the calculated taxes.
Thus, the deduction probably must respect the proportion of the non-cooperative act. The Federal Revenue Service has expressed its views on technological innovation incentives and on the Worker’s Food Program (PAT), which shows a possible similar interpretation, although no specific understandings have been found for donations made to NGOs.
It should be noted that the tax benefit related to technological innovation is provided for in Law No. 11.196/2005[20] and replicated by the Income Tax Regulations, which authorizes the deduction, in the calculation of net income, of expenses with technological research and technological innovation development. As for the tax incentive related to PAT, Law No. 6.321/76[21] authorizes the deduction in taxable income for IRPJ calculation purposes, while Decree No. 10.854/2021[22] establishes that the deduction occurs in the income tax due.
On the other hand, specifically regarding the tax incentive related to the deduction of the amount donated to NGOs, art. 13, § 2º, item III of Law No. 9,249/95[13] authorizes the deduction of the donation in the calculation of real profit, similar to what is provided for in the case of the PAT. The laws that authorize the deduction of PAT and investments in technology have different content and wording from art. 13, § 2º, item III of Law No. 9,249/95[13], and no specific Consultation Rulings were found regarding this latter authorization. Furthermore, in the case under analysis, the questioning about any restrictive interpretation by the Federal Revenue Service is considered legally plausible.
This is because, initially, in the specific case of art. 13, § 2º, item III of Law No. 9.249/95, distinct from the provisions, for example, in Law No. 11.196/2005[20], which deals with technological innovations, the wording provides for the possibility of deducting the donation when calculating the actual profit, and not the net profit, as occurs in the case of innovation expenses. Thus, the moment of calculating the actual profit corresponds to the phase in which additions and exclusions are made, which allows for the interpretation of the possibility of excluding the entirety of the donation made and not just the proportion related to non-cooperative acts, respecting the limit of 2% of the operating profit.
Secondly, as observed in the content of Article 13 itself, which generally prohibits the deduction of donations, paragraph 2 establishes an exception with the objective of encouraging donations through the granting of tax benefits. From this perspective, it is argued that the entirety of expenses related to the donation may be deducted from the due income tax, with the disregard of the proportionalization between cooperative and non-cooperative acts, because, otherwise, the purpose of the norm to encourage taxpayers to make donations would be frustrated.
In any case, this is unprecedented argumentation, as no judicial or administrative precedents discussing the issue have been identified. For this reason, it became necessary to analyze the accounting and fiscal scenarios of the cooperatives object of the study, referring to the 2021 fiscal year, in addition to projecting potential gains arising from the use of tax incentives related to the deduction of donations in the calculation of real profit.
That said, the accounting and fiscal scenarios of the analyzed cooperatives are presented in Table 1.
Table 1. Result before taxes and participations – Fiscal Year 2021
| Medical Cooperatives | 2021 Exercise (In Reais – BRL) |
| Cooperative (A) | 21.397.023 |
| Cooperative (B) | 31.757.974 |
| Cooperative (C) | 3.453.239,34 |
| Cooperative (D) | 12.482.611 |
| Cooperative (E) | 3.533.538 |
In Table 2, the values of the Corporate Tax/ Income Tax On Legal Person [IRPJ] for the analyzed period are presented.
Table 2. Corporate Income Tax Values – Fiscal Year 2021
| Medical Cooperatives | 2021 Exercise (In Reais – BRL) |
| Cooperative (A) | 5.095.577 |
| Cooperative (B) | 563.712 |
| Cooperative (C) | 427.019 |
| Cooperative (D) | 448.410 |
| Cooperative (E) | 123.912 |
As shown in Table 1, the results for the 2021 fiscal year before the incidence of taxes and participations are presented. Table 2 correlates the determined values of Corporate Tax/ Income Tax On Legal Person. In the presented scenario, a significant discrepancy is observed between the results of the 2021 fiscal year of the analyzed medical cooperatives. Management factors, increased claims experience of beneficiary portfolios, non-payment, and the entry of major players in the supplementary health sector impacted the results of the period.
The result of the exercise is an important metric for organizations operating in the supplementary health sector. In this context, cooperative and non-cooperative acts perform distinct and equally significant functions. The segregation of these acts allows cooperatives to transparently demonstrate their activities and results to regulatory bodies and members. Table 3 presents the scenario of the analyzed medical cooperatives regarding the treatment of acts.
Table 3. Result of cooperative and non-cooperative acts – Fiscal Year 2021
| Medical Cooperatives | Result of cooperative acts (In real-R$) | Result of non-cooperative actions (In BRL) |
| Cooperative (A) | 6.792.994 | 4.374.213 |
| Cooperative (B) | 93.289.607 | – |
| Cooperative (C) | 282.399.998 | – |
| Cooperative (D) | 8.759.586,81 | – |
| Cooperative (E) | 32.961.684 | – |
In Table 3, it is verified that only the medical cooperative A performs the segregation of the results of cooperative and non-cooperative acts. As determined in the Income Statements for the year 2021, cooperative A segregated the revenue from medical-hospital assistance premiums and initially defined the proportionality of cooperative and non-cooperative acts on net compensable events.
Some revenues and expenses were determined with differentiated criteria, such as financial investment revenue, which was directly allocated as a non-cooperative act, and revenues and expenses as own means, directly allocated as a cooperative act. Given the presented context, it should be highlighted that the resolution of the issue lies in the segregation of cooperative and non-cooperative acts. The economic-financial movement of medical cooperative societies must demonstrate, in a segregated manner, the composition of the year’s result in cooperative and non-cooperative acts in the Statement of Income, with the results determined by service, presented jointly.
Based on the adopted practice, it is possible to apply the deductions provided for in tax incentive laws, conservatively, to the result of non-cooperative acts, since they are taxable and, therefore, uncontroversially eligible for such an operation. Table 4 below presents the projection of the scenario based on the applicability of the incentive percentage granted by Law No. 9,249/95.
Table 4. Deduction of the 2% percentage of non-cooperative acts – Fiscal Year 2021
| Medical Cooperatives | 2% deduction on the result of non-cooperative acts (In Brazilian Real – R$) | Tax base for calculation of Corporate Tax (in Reais – R$) |
| Cooperative (A) | 87.484 | 4.286.728 |
| Cooperative (B) | – | – |
| Cooperative (C) | – | – |
| Cooperative (D) | – | – |
| Cooperative (E) | – | – |
Source: Original research results.
In Table 5, the Income Tax calculation is presented after deductions for tax incentives for the year 2021, in accordance with the standard of the other tables.
Table 5. Calculation of Corporate Tax/ Income Tax On Legal Person after tax incentive deductions – Fiscal Year 2021
| Medical Cooperatives | Value (In BRL – BRL) |
| Cooperative (A) | 1.886.023 |
| Cooperative (B) | – |
| Cooperative (C) | – |
| Cooperative (D) | – |
| Cooperative (E) | – |
The segregation of revenues, expenses, and costs arising from activities unrelated to the cooperative act is necessary for the result of these activities to be correctly determined and to observe the corporate and fiscal aspects. Thus, transactions must be demonstrated, identifying parties as members and non-members, income, revenues, transfers, expenditures, costs, and expenses, all allocated according to their nature, with funds and reserves, losses, and interest on share capital duly considered.
It should be noted that the accounting record segregated between cooperative and non-cooperative acts generates tax effects, since cooperative societies, in accordance with specific legislation, will pay the tax calculated exclusively on the positive results arising from non-cooperative acts.
In this sense, regarding the incidence of taxes, the positive result of cooperative act operations must be excluded from the calculation base for IR taxation purposes. The negative result of the cooperative act must be added to the result of the fiscal year for the calculation of taxable income, with the adjustment recorded in the Real Profit Calculation Book (LALUR), present in the Fiscal Accounting Record (ECF). As for the net result of operations with third parties (non-cooperative act), it must be fully allocated to the Technical, Educational and Social Assistance Fund (FATES).
It is worth noting that the medical cooperatives analyzed have a taxation regime under the actual profit. In this way, the calculation of the IR on net profit, according to the adopted regime, has as its calculation basis the accounting profit recorded in the cooperative’s commercial accounting (result of non-cooperative act), with adjustments made in the form of additions, exclusions, or compensations, in accordance with the legislation applicable to IRPJ and CSLL, and the calculation occurs quarterly or annually.
In the calculation of the actual profit, as mentioned, it is possible to use tax incentives to reduce the tax burden in the transfer of the tax, such as, for example, in the case of expenses with donations, which must be submitted to a pro rata distribution based on the proportionality between gross income (cooperative acts) and gross revenue (non-cooperative acts). Only the proportional share of the expense that reduced the taxable result (non-cooperative act) should be added to the tax calculation base.
On the other hand, despite the uncertain scenario and the absence of precedents on the subject, the taxpayer, supported by the literal wording of art. 13, § 2º, item III of Law No. 9,249/95[13], which provides for the possibility of deducting the donation in the calculation of real profit, i.e., at the moment of additions and exclusions, could risk excluding the entirety of the donation made, and not just the portion corresponding to non-cooperative acts, in an innovative, yet reckless manner. The present study analyzed the applicability of benefits related to tax incentives on the results of acts practiced by medical cooperatives, both cooperative acts, aimed at the performance of their cooperative doctors, and non-cooperative acts, arising from operations carried out with third parties unrelated to the main objective.
Based on the premise presented, it is concluded that the deduction of 2% of operating profit for donations made to NGOs represents an important tool in the fiscal context and in promoting corporate social responsibility. Although aimed at non-cooperative acts, this measure generates significant benefits for both medical cooperatives and NGOs and positively impacts the well-being of society in general. However, the importance of transparency, compliance with tax obligations, and maintenance of adequate records when using this deduction is highlighted.
For companies and cooperatives in general, this deduction not only provides tax incentives but also allows them to play an active role in solving social problems and promoting initiatives beneficial to the community. The measure meets the growing demand for socially responsible companies that seek to generate positive impact beyond financial results.
This study presents as its main limitation the analysis restricted to five medical cooperatives in specific regions of Minas Gerais, which prevents the full generalization of the results to the entire health cooperative system in Brazil. Furthermore, the reliance on public data made available on institutional websites may have limited the in-depth analysis of some accounting and fiscal aspects, especially in cooperatives that do not show segregation between cooperative and non-cooperative acts.
As a future research agenda, it is recommended to expand the investigation to a larger set of health cooperatives in different regions of the country, as well as to include comparisons with cooperatives from other sectors, in order to verify the applicability of tax incentives in different contexts. Broader quantitative studies and longitudinal analyses can contribute to understanding the evolution of tax treatment in the sector. The analysis of the perception of managers and regulatory bodies regarding the difficulties of accounting segregation and the opportunities for improving tax legislation applicable to cooperatives is also recommended.
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COMO CITAR:
Zanini, N.M.; Pereira, B.S.2025. Planejamento tributário: incentivos fiscais para cooperativas de saúde Revista E&S; 6: e2024073.
ABOUT THE AUTHORS:
Natália Mucida Zanini – Specialist in Tax Management. Tax lawyer. Marcela Guimarães e Associados Law Firm. Avenida Rondon Pacheco, 4600, Uberlândia Business Tower, Tibery, 38405-142, Uberlândia, Minas Gerais, Brazil.
Beatriz da Silva Pereira – Advisor professor. Rua Engenheiro Agronômico Andrei Cristian Ferreira, s/n, Trindade, 88040-900, Florianópolis, Santa Catarina, Brazil.