Introducing the new identity of NSS.
If you are a doctor in Chile and issue fee receipts (boletas de honorarios), you are paying taxes on your gross income with a very limited ability to deduct what it actually costs you to practice your profession. The difference between operating as an individual and doing so through a properly structured medical corporation can mean tens of millions of pesos per year in tax efficiency, reinvestment, and wealth building.
This guide explains how healthcare professionals with an established practice are reorganizing their structure to achieve better taxation: an operating SpA under the Pro Pyme Regime (Article 14, Section D, No. 3 of the Income Tax Law, or LIR) and, above it, an investment company that acts as a wealth-holding entity.
This is not a tax evasion scheme or a gray area. It is legal tax planning, endorsed by the SII, and it is the standard currently used by professionals who manage their wealth seriously.
A doctor who practices independently is a Second Category taxpayer and is taxed under the Global Complementary Tax (IGC). The mechanism works as follows:
The fundamental problem: there is no deduction for actual expenses and no possibility of deferral. Everything received during the year is taxed immediately, regardless of how much was spent to generate it or whether it is reinvested.
The 30% presumed expenses have an absolute ceiling of 15 UTA, equivalent to approximately $12,150,000 CLP per year (based on a UTA of $810,000). This benefit is fully exhausted when gross income reaches 50 UTA, that is, approximately $40,500,000 per year or $3,375,000 per month.
For anyone billing above that threshold, the impact is direct and increasing. If a doctor generates $120 million per year, the theoretical 30% would be $36 million. But the system only recognizes $12.15 million: nearly $24 million in deductions are lost and go straight into the taxable base. The law, furthermore, does not allow claiming actual expenses above this cap under the fee receipt framework.
This is the progressive scale that applies to doctors who file taxes as individuals:
Starting at approximately $60 million CLP in annual billing (about $5 million per month), fee receipts become a tax-inefficient mechanism due to three compounding effects:
A doctor with $60M in annual income and $25M in actual expenses ends up paying between $3M and $3.9M more than they would under a corporate structure. This additional cost is not the result of an audit or a violation. It is simply the consequence of not having optimized the structure in time.
The Sociedad por Acciones (SpA) is the most commonly used vehicle for this purpose due to its flexibility: it can have a single shareholder, allows customizable bylaws, and its incorporation is fast. By opting into the Pro Pyme General Regime under Article 14 D No. 3 of the Income Tax Law, the company obtains three structural advantages that radically change the doctor's tax scenario.
Under Article 31 of the LIR, the SpA can deduct from its income all expenses necessary to generate revenue, without the arbitrary ceiling of 15 UTA. In practical terms, this means the doctor can deduct:
All of this becomes an actual deduction against the company's taxable base, not a fictitious number arbitrarily capped. The company's taxable result is calculated on effective profit, not on gross income.
Profits that remain within the SpA are subject to the First Category Tax under the Pro Pyme Regime, whose transitional rate is currently 15% (with a base rate of 25% once the transitional period expires). This contrasts directly with the marginal IGC rates that the same doctor would face as an individual:
As long as profits are not withdrawn by the doctor as an individual, they are not subject to the Global Complementary Tax. This deferral is significant: it allows funding the purchase of office space, the acquisition of high-tech equipment, or participation in medical centers with pre-tax profits, all without having first gone through the 35% or 40% marginal rate.
In simple terms: the doctor decides when to withdraw and, therefore, when to pay personal tax. That is management power that fee receipts do not offer.
It is completely legitimate to maintain fee receipts for institutions that require them (clinics, hospitals, mutual insurance companies) while simultaneously channeling private consultations, telemedicine, and teaching through the SpA. This mixed structure is common, well-regarded by the SII, and creates no legal incompatibility.
Once the medical SpA is operating and generating surpluses that the doctor does not need to withdraw for current living expenses, the next step is to establish an investment company that acts as a wealth-holding entity, positioned above the operating SpA.
Profits distributed by the medical SpA to the holding company do not trigger IGC, because Article 33 No. 5 of the LIR excludes dividends received by companies from the IGC taxable base. The money moves up from the operating company to the holding at no additional tax cost. Once in the holding, it can be freely reinvested.
The investment company can allocate the accumulated wealth to:
The holding additionally fulfills two long-term functions that should not be underestimated:
Asset protection: the separation between the operating company and the holding protects accumulated wealth against risks inherent to medical practice, including malpractice lawsuits or commercial contingencies. The holding's assets are not directly exposed to the operating SpA's liabilities.
Estate planning: transferring shares in a company is legally simpler, less costly, and more orderly than directly inheriting assets. The doctor can define today how their wealth will be distributed, with the corresponding shares for each heir, without the need for forced liquidations.
This arrangement is not for every doctor, but it is not exclusive to large estates either. The criterion is not the size of accumulated capital but the dynamics of income and expenses. The structure begins to make sense when at least two or three of the following conditions are met:
The tax planning described here is completely legal. It is neither evasion nor elusive in the legal sense of the term. But it has compliance requirements that must be respected, and the SII actively audits them.
The SpA cannot be a shell company. It must operate effectively: have service contracts, issue invoices consistent with the declared level of activity, maintain its own bank accounts, and keep full accounting records. The SII can challenge a structure that lacks real economic substance.
Only expenses that are necessary to generate the company's income can be deducted. Charging the company for groceries, family vacations, or children's school tuition is not only technically incorrect: if the SII disallows them, it applies a penalty equivalent to 40% of the rejected expense, pursuant to Article 21 of the LIR. The criterion is not what seems reasonable to the taxpayer; it is what the SII considers linked to income generation.
The structure must have a genuine economic purpose beyond tax savings. The Tax Code includes a general anti-avoidance rule that allows the SII to disregard or recharacterize acts that, although formally legal, were designed exclusively to obtain a tax advantage without real economic substance. An SpA that never invoices, has no contracts, and whose accounts show no coherent medical activity is vulnerable to this type of challenge.
In practice, a properly designed and operated structure has no issues with the SII. The risk arises when things are improvised, when expenses are not documented, or when there is no advisor maintaining the accounting and contracts up to date.
Yes, in a completely legitimate mixed structure. Fee receipts continue for institutions that require them; the SpA invoices for private and independent activity. There is no legal or tax incompatibility between both arrangements.
Only when you withdraw dividends from the SpA to yourself as an individual. As long as the money remains in the company, the IGC is not triggered. When you withdraw, you pay IGC on the amount withdrawn, with a credit for the First Category Tax already paid by the company.
No. The operating SpA is the first step and can function perfectly on its own. The holding is added when the SpA begins generating surpluses that the doctor does not withdraw, because that is where the opportunity to reinvest without additional tax cost appears. Many doctors start with just the SpA and add the holding one or two years later, when their wealth justifies it.
Partially. Salary received under an employment contract is taxed as employment income through withholding and cannot be channeled through the SpA. However, if that same doctor additionally has a private practice, teaches, provides telemedicine services, or works shifts on a fee basis, that part of their activity can be organized through the company.
The Pro Pyme Regime allows deducting 100% of the value of fixed assets acquired in the same fiscal year they are purchased. This means that if the SpA buys diagnostic equipment for $15 million, it can deduct that entire amount from its taxable base that year, instead of amortizing it over several fiscal years. For a medical practice that requires expensive equipment, this has a significant tax impact.
A doctor with an established practice who files taxes exclusively as an individual through fee receipts is silently and steadily losing financial efficiency. Not because they are doing something wrong, but because the Chilean tax system, as designed, was not built to optimize the situation of a high-income professional with significant actual expenses.
The SpA Pro Pyme + Holding architecture is today the standard for serious wealth management among doctors in Chile. It allows deducting what is actually spent, paying taxes on effective profit, deferring personal income tax until the right moment to withdraw, and building wealth with money that has not passed through the system's highest rates.
Implementing it correctly from the start avoids costs, risks, and improvisation. What is not advisable is waiting until the accumulated cost is so evident that it can no longer be ignored.
At NSS Corporate & Tax, we support healthcare professionals through this entire process: from the initial tax assessment to the incorporation of companies, the design of the withdrawal structure, and ongoing compliance with the SII. We know what the SII requires, what the law allows, and how to maintain a structure that works over time without surprises.