How to form sustainable prices during the transition of the Consumption Reforma Tributaria

Technical article • Updated on August 24, 2026

Marli Voss Hartmann da Silva

Versátilis Accounting Studies and Concepts

Executive summary

The tax reform changes the pricing logic in the health sector because IBS and CBS adopt a consumption taxation model with broader credits, exclusive incidence, and differentiated treatments. Complementary Law No. 214/2025 reduces IBS and CBS rates by 60% for health services expressly listed in its Annex III. This does not mean a final rate of 60%, but rather the application of 40% of the standard rate. Since the definitive standard rate depends on acts by the competent entities, the price should not be set based on a single estimate.

The best methodology is hybrid: (1) measure care costs per procedure; (2) allocate fixed costs based on practical capacity, rather than idealized occupancy; (3) add commercial expenses and desired margin; (4) estimate the IBS/CBS debit and the credits actually claimable; and (5) test scenarios by tax regime, client profile, and transition phase. The result is a technically defensible price, subject to review and aligned with the sustainability of care.

1. What really changes for healthcare

Constitutional Amendment No. 132/2023 created the constitutional basis for the new consumption taxation system. The main regulation came with Complementary Law No. 214/2025, subsequently adjusted by Complementary Law No. 227/2026. For health services listed in Annex III of LC No. 214/2025, art. 130 provides for a 60% reduction in IBS and CBS rates. Amounts disallowed by the medical audit of health insurance plans and not paid are not included in the tax base of these taxes.

The benefit must be confirmed by the classification of the service in the Brazilian Service Nomenclature (NBS) and by the operation actually provided. One should not assume that all revenue earned by a healthcare company receives the same treatment. Sale of products, leasing, administrative activities, ancillary services, medications, medical devices, and health care plans may follow different rules.

2. The safest methodology: price per procedure

The recommended method starts with the procedure, consultation, exam, session, or hospital daily rate. The goal is to find the unit economic cost before margin and taxes. To do so, the organization must maintain care and support cost centers, control room and team time, record material consumption, and use a realistic occupancy rate.

Define the pricing unit

Consultation, examination, session, procedure, daily rate, therapeutic package, or monthly contract.

2. Gather direct costs

Proportional fees and assistance salaries, medications, materials, outsourced exams, charges, and disposables.

3. Allocate indirect costs

Reception, billing, cleaning, technology, maintenance, depreciation, rent, energy, and management.

4. Adjustment by practical capacity

Divide fixed costs by realistically available hours or appointments, deducting vacations, maintenance, absences, and normal idle time.

5. Include expenses and risks

Card fees, defaults, expected disallowances, commissions, contingencies, and administrative expenses.

6. Model net IBS/CBS

Calculate the debit on the transaction, subtract only credits supported by documents, and respect the taxpayer's regime.

7. Apply the margin and test the market.

Compare with perceived value, competition, agreement tables, elasticity, and payment capacity.

3. Managerial Formula for Pricing

For contracts in which the clinic needs to define a total price that absorbs proportional expenses, tax risk, and margin, the following management formula can be used:

The “net tax burden” is a management premise: estimated IBS/CBS debit less eligible credits, expressed as a percentage of revenue. It does not replace fiscal tax assessment. When the fiscal document shows IBS/CBS as a separate item, the system must separate the transaction's base price, the tax amount shown, and the total charged, in accordance with current rules.

4. Practical example: multiprofessional clinic

Consider a consultation with the following hypothetical values. The clinic is under the regular IBS/CBS regime, the service was confirmed in Annex III, and management wants a 20% margin on revenue. The example is didactic and does not represent an official definitive rate.

Calculation: R$ 190.00 ÷ [1 − (8% + 9% + 20%)] = R$ 190.00 ÷ 0.63 = R$ 301.59. Thus, R$ 301.59 is the managerial price needed to cover the adopted assumptions. If the estimated credits drop, the break-even price rises; if the clinic increases occupancy or reduces denials, the unit cost and the required price may fall.

5. Sensitivity analysis

Since the definitive standard rate should not be treated as a fixed number, management needs to work with scenarios. Keeping the other premises of the example unchanged, with credits equivalent to 2.2% of revenue:

Correct reading: The legal reduction improves health treatment, but the final effect depends on the level of the standard rate, credits, tax regime, cost structure, and the commercial possibility of passing costs on.

6. Simples Nacional, presumed profit and actual profit

The choice of regime remains decisive. Companies under Simples Nacional remain subject to the specific rules of LC No. 123/2006 and to the options provided in the new system. It is not technically correct to automatically apply the estimated reduced rate of the regular regime to every service provider opting for Simples. Companies outside Simples, in turn, need to integrate IBS/CBS into the joint analysis of IRPJ, CSLL, payroll, withholdings, and sectoral obligations.

Simples Nacional: Compare the DAS burden, the potential for transferring credits to the client, the B2C/B2B mix, and any option provided for IBS/CBS. The decision should not consider only the nominal rate.

Lucro Presumido: Project IRPJ and CSLL according to the applicable presumed bases, in addition to the transition from PIS/Cofins to CBS and from ISS to IBS. Monitor withholdings and contracts.

Actual Profit: Reconcile accounting and tax margins, take advantage of credits when legally permitted, and control documentation by cost center, establishment, and nature of the operation.

7. Sector particularities that must be included in the price

Disallowances and Default

Unpaid disallowances have a specific rule for exclusion from the base for the covered services, but they continue to affect cash flow, productivity, and contractual risk.

Labor-intensive

Payroll and pro-labore do not, as a rule, generate the same pattern of credits from taxed acquisitions. Labor-intensive service providers may have proportionally lower credits.

Assets and technology

Equipment, software, and maintenance require documentary and credit eligibility analysis, in addition to economic depreciation in the cost.

Agreements

Schedules, deadlines, disallowances, and packages can prevent immediate pass-through. The contract must provide for tax review and scope changes.

Private and B2B service

Individual patients do not take advantage of credits; acquiring companies may value the regularity of the credit. Commercial strategy and pricing may differ.

Ancillary revenues

Parking, product sales, aesthetics services not otherwise classified, leasing, and other revenues must be classified separately.

8. 90-Day Implementation Plan

9. Indicators to review monthly

Pricing should be dynamic. It is recommended to track cost per procedure, contribution margin, occupancy rate, average service time, denial rate, average collection period, IBS/CBS debit, recognized credits, net tax burden, profitability per health plan, and variance between standard cost and actual cost.

Conclusion

The best way to price healthcare services under tax reform is not to add a generic percentage to the current price. It is to build a price per procedure based on reliable costs, practical capacity, commercial risk, margin, and taxation net of credits. The 60% reduction provided for healthcare services listed in Annex III is relevant, but it must be applied to the applicable standard rate and only after the correct classification of the transaction.

In 2026, a test year, the priority is to prepare registrations, tax documents, systems, contracts, and cost data. A clinic that knows its margin per service can adjust prices gradually, negotiate with health insurance providers on a technical basis, and prevent the tax transition from compromising financial sustainability or patient access.

References

BRAZIL. Constitutional Amendment No. 132, of December 20, 2023. https://www.planalto.gov.br/ccivil_03/constituicao/emendas/emc/emc132.htm

BRAZIL. Complementary Law No. 214, of January 16, 2025. Establishes IBS, CBS, and Selective Tax. https://www.planalto.gov.br/ccivil_03/leis/lcp/lcp214.htm

BRAZIL. Complementary Law No. 227, of January 13, 2026. Establishes the IBS Managing Committee and amends Complementary Law No. 214/2025. https://www.planalto.gov.br/ccivil_03/leis/lcp/lcp227.htm

FEDERAL REVENUE OF BRAZIL. Understand the Consumption Tax Reform (Reforma Tributaria). https://www.gov.br/receitafederal/pt-br/acesso-a-informacao/acoes-e-programas/programas-e-atividades/reforma-tributaria-do-consumo/entenda

BRAZILIAN FEDERAL REVENUE. Guidelines for the 2026 Reforma Tributária. Updated on May 6, 2026. https://www.gov.br/receitafederal/pt-br/acesso-a-informacao/acoes-e-programas/programas-e-atividades/reforma-tributaria-do-consumo/orientacoes-2026

IBS STEERING COMMITTEE. CGIBS Resolution No. 6, of April 30, 2026. Regulates the IBS. https://www.cgibs.gov.br/upload/arquivos/202604/30084927-res-cgibs-n-6-30-abr-2026-regulamenta-o-ibs.pdf

Access to electronic sources on: Aug. 24, 2026.