Introducing the new identity of NSS.
From Professional Service Invoices to Asset Holding Companies. A Technical and Practical Guide.
Advanced Tax Guide for Healthcare Professionals | NSS Corporate & Tax | 2026
Taxation for physicians in Chile is not a matter of basic accounting. It's an architectural decision that determines how much wealth is built, how much is protected, and how much is transferred to future generations. However, most healthcare professionals reach their peak earning years operating exactly as they did when they started: issuing professional service invoices, paying the Global Complementary Tax at marginal rates of up to 40%, and without any structure that allows them to defer, reinvest, or protect.
This guide covers the full spectrum of tax planning available to a physician in Chile, from the initial stage of professional service invoices to the formation of holding companies and real estate companies. Each stage has its own logic, legal instruments, and efficiency conditions. The goal is not to describe all possible options, but to explain when each applies, the cost of not using it, and how to transition from one stage to the next.
Everything described is legal tax planning, endorsed by the SII (Chilean Internal Revenue Service) and consistent with current regulations. The difference between those who implement it and those who don't is not legal: it's economic.
Every physician practicing independently starts as a Category Two taxpayer. The mechanism is well-known: professional service invoices are issued, the institution or patient withholds 14.5% as an advance payment, and at the close of the tax year, the income tax return is filed, consolidating all income under the Global Complementary Tax.
In their early years of practice, this scheme is functional. Income is moderate, the marginal rate is low, and the 30% deduction for presumed expenses is sufficient to reasonably absorb the costs of the activity. The problem arises when income scales up and the tax system, which was not designed to optimize the situation of a high-performing professional, begins to work against them.
The tax calculation works as follows:
There are two inherent problems in this mechanism that are amplified as income grows. The first is the progressivity of the GCT. The second, and less discussed, is the cap on presumed expenses.
The Global Complementary Tax scale for the 2026 tax year is as follows:
A specialist physician earning CLP 80 million annually is paying a marginal rate of 30.4% on each additional peso. One exceeding CLP 97 million enters the 35% bracket. From CLP 251 million, it's 40%. These are not theoretical rates: they are the real cost of every income decision that has not been planned.
The law allows for a 30% deduction of gross fees as presumptive expenses. This seems generous. However, this 30% has an absolute annual cap of 15 UTAs, equivalent to approximately $12,150,000. The benefit is completely exhausted when gross income reaches 50 UTAs (~$40,500,000). Beyond this point, the doctor pays taxes on the excess without any further deductions possible under the fee receipt system.
The law does not allow claiming actual expenses above this cap under the fee receipt system. Even if a doctor can prove they spent $30 million on renting their practice, hiring staff, and financing their equipment, the system only recognizes $12.15 million. The rest goes directly into the taxable base.
A doctor who bills $200 million annually and has $47 million in non-deductible actual expenses is paying taxes on nearly four times the value of a home. This is the concrete and measurable cost of not having a proper business structure.
The 50 UTAs (~$40.5 million annually or ~$3.375 million monthly) represent the true inefficiency threshold. Below this level, the fee receipt system with presumptive expenses is a reasonably functional mechanism. Above it, it becomes a silent tax trap. The following table illustrates this with a typical case:
Savings aren't the only benefit: the SpA gives the doctor control over when they pay personal taxes. This flexibility, compounded over time, is as valuable as the tax rate differential.
Before analyzing the SpA under the Pro Pyme Regime, it's worth understanding an entity that many doctors know by name but few have properly implemented: the Professional Partnership. Its main appeal isn't the tax rate, but something different: the VAT exemption.
A Professional Partnership is an entity whose sole purpose is the provision of professional services by its partners, who are natural persons with recognized professional qualifications. Under Article 42 N2 of the LIR, it can choose to be taxed under the Second Category (as if each partner were an independent worker) or the First Category.
The key advantage is tax-related, not directly about the rate: medical services provided by natural persons are VAT exempt according to Article 12 letter E N14 of DL 825. If the partnership maintains its classification as a Professional Partnership and operates exclusively through its qualified natural person partners, this exemption is transferred to the entity. If the partnership hires non-partner staff to provide services or diversifies its purpose, it may lose the exemption and become subject to 19% VAT on its fees.
For a doctor who primarily bills natural persons or ISAPRE patients, that 19% can be a definitive, unrecoverable cost. Maintaining the exemption is not a minor detail: it is a requirement for the economic viability of the model.
The requirements demanded by the SII and clarified by administrative jurisprudence are as follows:
The transition from a fee receipt system to a Professional Partnership is neither automatic nor immediate. It requires a precise sequence of steps to avoid generating tax contingencies during the process:
The most critical aspect of this process is the consistency between actual operations and documentation. The SII doesn't just review the bylaws: it examines contracts, cash flows, the identity of those who actually provide the services, and the consistency between what is billed and what is declared.
The Professional Company solves the VAT problem, but not that of the IGC rate or deferral. Profits continue to be taxed under the attribution or withdrawal scheme in the hands of individual partners, at marginal rates that can reach 40%. For a high-income doctor who wants to reinvest profits without immediate taxation, the Professional Company has an efficiency ceiling.
That's where the SpA under the Pro Pyme Regime comes in, combining the deduction of actual expenses with IGC deferral and the reduced First Category rate.
The Stock Company (SpA) under the General Pro Pyme Regime of Article 14 D N3 of the Income Tax Law is currently the standard for doctors with an established practice in Chile. Its advantage is not singular: it's a combination of three benefits that operate simultaneously and are mutually reinforcing.
Under Article 31 of the LIR, the SpA can deduct from its taxable income all expenses necessary to generate income. There is no 15 UTA limit. The criterion is the necessity and relevance of the expense for the income-generating activity. In practice, a doctor can deduct:
Retained earnings in the SpA are subject to First Category Income Tax (IDPC), not Global Complementary Tax (IGC). Law 21,755 of 2025 established a temporary rate reduction for Pro Pyme companies:
Additionally, the Pro Pyme regime allows for immediate depreciation: 100% of the value of acquired fixed assets can be deducted from the taxable base in the same fiscal year they are purchased. For a doctor investing in high-cost diagnostic equipment, this has an immediate and tangible impact on the tax burden in the year of acquisition.
The Global Complementary Tax (IGC) is only incurred when the doctor withdraws dividends or profits to their personal capacity. As long as the money remains in the SpA, it only pays the Pro Pyme First Category Income Tax (IDPC) (12.5% today) and remains available for reinvestment. This deferral is not a minor benefit: in terms of present value, money that is not taxed at 35% or 40% today and is reinvested in the company compounds at an effectively higher rate.
In practical terms: the doctor decides when to pay personal taxes. They can withdraw only what they need for current consumption, pay IGC on that, and leave the rest in the company to generate returns without incurring the maximum tax rate.
One of the most frequent questions is whether it's possible to maintain an employment contract with a hospital or clinic while simultaneously operating an SpA. The answer is yes, and designing the mix is one of the most relevant decisions in a doctor's tax planning.
The optimal mix design depends on the relative proportion of each income source, the level of professional expenses, and how much the doctor intends to reinvest versus consume. There is no single formula: it's a case-by-case evaluation.
When the medical SpA begins to generate profits that the doctor does not need to withdraw immediately, the following question arises: where will these profits reside? If withdrawn, they incur IGC. If they remain in the operating SpA, they are exposed to the risks of that activity. The answer is an Investment Company, or Holding Company.
The holding company is neither a tax evasion instrument nor an exotic entity. It is the standard vehicle used by organized wealth in Chile to separate operational activity from assets, manage investments, and plan for intergenerational transfer.
The typical architecture operates on three levels:
The key point is the flow between Level 3 and Level 2: dividends distributed by the medical SpA to the holding company do not generate Global Complementary Tax (IGC). Article 33 N5 of the Income Tax Law (LIR) excludes dividends received between companies from the IGC taxable base. Capital moves from the operating company to the holding company without additional tax cost. Only when the doctor withdraws funds from the holding company to their personal capacity is the IGC triggered.
Medical practice has a risk profile that is not always evaluated in its wealth dimension. A malpractice lawsuit, an employment contingency with a practice employee, or a commercial debt related to equipment can, in extreme scenarios, affect personal assets if there is no structural separation.
The holding company elegantly solves this problem: accumulated assets (real estate, portfolios, stakes in other businesses) reside within the investment company, not the operating SpA. If the operating SpA faces a contingency, the holding company's assets are not directly exposed. The legal separation between the two entities acts as a barrier.
This separation is not inviolable, nor does it exempt from personal liability in all cases (especially in direct tort liability), but it significantly reduces the scope of asset risk in the face of ordinary operational contingencies.
The most powerful argument for the holding company is not the tax rate: it's the effect of compound capital on profits that have not yet paid IGC. A doctor who withdraws $40 million and pays 35% IGC receives $26 million net to invest. One who does not withdraw those $40 million and leaves them in the holding company invests the full amount. Over time, the difference between investing $40 million and $26 million, compounded at any reasonable rate, is substantial.
This mechanism does not avoid the tax: it defers it. When the doctor finally withdraws from the holding company, they will pay IGC on the amount withdrawn. But until then, the capital has worked in its entirety, not just the 65% remaining after tax.
When a doctor begins to acquire real estate, the question of whose name to buy it under is not trivial. It has implications for VAT, the treatment of capital gains, deductible depreciation, asset protection, and estate planning. The correct answer depends on the asset's profile, the intended use of the property, and the taxpayer's scale.
When real estate is acquired or managed through an SpA, the applicable tax regime depends on the type of company and the use of the property:
Since Law 21.210 of 2020, the habitual sale of real estate is subject to VAT in accordance with Article 2 N1 and Article 8 letter m) of DL 825. Habituality is no longer automatically presumed by the business activity: it is analyzed on a case-by-case basis, considering the frequency of sales, the amount, the speculative intent, and whether the company's corporate purpose includes the buying and selling of real estate.
For a doctor whose real estate SpA aims to lease and hold assets, rather than engage in recurrent buying and selling, this risk is manageable. The key is that the corporate purpose, actual operations, and transaction frequency are consistent with an investor profile, not a real estate developer. The SII can initiate activities and assign habituality even if the bylaws do not foresee it, if the taxpayer's conduct reflects a habitual activity.
Tax depreciation of real estate operates under Article 31 N5 of the LIR and applies exclusively to the value of the building, not the land. The available modalities are:
For a doctor who acquires their consultation room or a clinical-use apartment through a Pro Pyme SpA, instant depreciation allows for deducting the total value of the building in the year of purchase. It is a first-rate tax planning tool that is not available to individuals.
Before Law 21.210, there was a presumption of habituality for construction companies. Today, that legal presumption does not exist: the SII must prove habituality on a case-by-case basis, evaluating the frequency, amount, intent, and conduct of the taxpayer.
For a doctor's real estate SpA, this means that if sales are sporadic, the asset has been held for a reasonable period, and the corporate purpose does not include buying and selling as a primary business activity, there is reasonable room to argue for the absence of habituality. However, this analysis must be done ex ante, not after the SII has already initiated an audit process.
Estate planning is the component most frequently deferred, usually with the argument that there will be time later. However, a well-designed asset structure from early on generates estate advantages that cannot be built retroactively.
Inheriting direct assets (real estate, vehicles, bank accounts) requires a probate process that involves inheritance tax under Law 16.271, registration procedures, valuations, and potential conflicts among heirs regarding valuation and division. Inheriting company shares is legally simpler: shares are transferred, and with them, all assets held by the company are transferred.
Additionally, the physician can design the asset distribution today: different ownership percentages for different heirs, corporate governance rules, and differentiated economic rights. All of this without needing to liquidate assets or face forced co-ownership of specific assets.
Law 16.271 taxes inheritances and donations with progressive rates. The tax base is the value of the assets transferred to each beneficiary, with exemptions and deductions based on the degree of kinship. Estate planning does not eliminate this tax, but it can spread it over time (lifetime gifts within exempt limits), diversify ownership (fractional interests), and reduce the taxable base through deductible liabilities.
A well-designed holding structure allows for the gradual transfer of interests, within the limits permitted by current regulations, without prematurely triggering inheritance tax. Long-term planning, in this regard, is significantly more efficient than a concentrated transfer at the time of death.
As the structure grows, reorganization may be required: separating assets, merging companies, dividing the holding company to assign interests to different family members, or segregating activities with different risk profiles. These operations receive special treatment under Article 14 of the LIR, which allows for tax-neutral reorganizations under certain conditions.
The Tax Code, in its Articles 4 bis and subsequent articles, includes the General Anti-Avoidance Rule (GAAR), which allows the SII to disregard reorganizations that lack real economic substance and whose sole purpose is to obtain a tax advantage. This does not prevent reorganization; it requires that any reorganization have a genuine economic justification beyond tax savings.
The architecture described in this guide is completely legal and designed within the current regulatory framework. However, it has compliance requirements that must be strictly observed. The SII has significantly increased its cross-auditing capacity and the use of massive data analysis to detect inconsistencies.
A well-designed structure avoids all these problems. Risks emerge when improvisation occurs, when documents are not up-to-date, or when expenses charged to the company are unrelated to the income-generating activity. The cost of ongoing advice is significantly lower than the cost of an audit.
The following table summarizes the available tools, the income threshold at which each becomes efficient, and the implementation priorities:
These stages are not isolated compartments, nor do they imply that someone in stage 2 cannot plan with a view towards stage 4. The optimal architecture is designed with the end goal in mind, not just solving this year's problem.
A physician's taxation in Chile is not an accounting problem. It is a strategic decision that determines how much of the income generated during the best years of professional productivity becomes real wealth, how much is protected from operational risks, and how much is efficiently transferred to those who come after.
The fee receipt is everyone's starting point, but it should not be the destination for anyone who has exceeded 50 UTA in annual income. Beyond that threshold, each year without a proper structure is a concrete and measurable cost that cannot be recovered.
The SpA Pro Pyme architecture, with a holding company and real estate company where applicable, is not a magic formula nor a set-it-and-forget-it decision. It is a system that requires design, careful implementation, and continuous management. Implementing it correctly from the start is significantly more valuable than correcting it after costs have already accumulated.
At NSS Corporate & Tax, we support healthcare professionals at every stage of this process: from the initial tax diagnosis to the reorganization of complex structures, the design of withdrawal schemes, and long-term estate planning. We know what the SII requires, what the law allows, and how to build a structure that works over time without surprises.
NSS Corporate & Tax | Tax and corporate advisory for high-performing professionals.