1. Legal Framework for Pharmaceutical Investment
Syria's Investment Law No. 18 of 2021, promulgated on May 19, 2021, forms the primary legal framework for pharmaceutical investment. The law explicitly prioritizes the pharmaceutical sector with substantial tax incentives and replaced Legislative Decree 8/2007.
Investment Law 18/2021 - Pharmaceutical Sector Provisions
- 50-75% income tax exemptions for industrial projects involving "technology, medicine, pharmaceuticals, renewable energy, waste recycling and crafts"
- 75% income tax reduction for 10 years in designated development areas
- Complete exemption from customs duties on equipment, machinery, assembly lines, and transport systems
- Raw material imports may be exempted from import bans when unavailable domestically
- Right to transfer profits abroad in convertible currency after settling taxes
Institutional Framework
The investment approval process operates through the Supreme Investment Council (chaired by the Prime Minister) for ultimate approval, with the Syrian Investment Agency (SIA) handling administrative functions through a one-stop investor services center. License approval occurs within 15 days after SIC review.
Presidential Decree 114/2025 - Post-Transition Reforms
Issued on July 9, 2025 by President Ahmad al-Sharaa, Decree 114/2025 substantially amended Investment Law 18/2021 following the December 2024 regime change.
- Established the Development Fund as an independent national financial-economic institution
- Strengthened property rights protections through judicial oversight
- Market-value compensation requirements for any expropriation
- Lifted restrictions on salary repatriation for expatriates
- Authorized international arbitration in disputes with the Syrian state
- Syrian Investment Authority restructured under direct presidential control
National Health Strategic Plan 2026-2028
The Ministry of Health launched the National Health Strategic Plan 2026-2028 in December 2025, with Director of Pharmaceutical Control Hani Baghdadi announcing priorities including:
Ministry of Health Strategic Priorities
- Localizing medicine production
- Encouraging factories to manufacture high-value medicines
- Raising GMP compliance standards
- Implementing "smart importing" to cover gaps without competing with local production
2. Foreign Ownership Rules by Sub-Sector
The pharmaceutical sector demonstrates Syria's differentiated approach to foreign investment: liberal rules for manufacturing and distribution, but professional restrictions on retail pharmacy ownership.
What Foreign Investors CAN Do (100% Ownership)
- Own 100% of pharmaceutical manufacturing facilities without mandatory Syrian partnership
- Establish wholly-owned pharmaceutical distribution companies
- Engage in drug import/export businesses with appropriate Ministry of Health registration
- Open bank accounts in Syrian pounds and foreign currencies
- Repatriate profits abroad in convertible currency
- Purchase and lease unlimited land for investment purposes
- Obtain residence permits for investors, families, and employees
What Foreign Investors CANNOT Do
- Own retail pharmacies directly - Syrian law restricts pharmacy ownership to registered Syrian pharmacists who must also serve as pharmacy managers
- Own agricultural land directly
- Establish single-shareholder LLCs when the owner is a foreign entity (must have 2-10 partners)
- Retain land ownership when an enterprise dissolves (must cede ownership)
Ownership Summary by Pharmaceutical Sub-Sector
| Sub-Sector | Foreign Ownership | Status |
|---|---|---|
| Drug Manufacturing | 100% permitted | Open |
| Pharmaceutical Distribution | 100% permitted | Open |
| Drug Import/Export | Permitted | Open |
| Medical Devices | Permitted | Open |
| API Manufacturing | 100% permitted | Open |
| Biologics/Biosimilars | 100% permitted | Open |
| Retail Pharmacy | Prohibited | Restricted |
Important Restriction: Retail Pharmacy Ownership
The Syrian Law of Practicing Medical Professions restricts pharmacy ownership to registered Syrian pharmacists who must also serve as pharmacy managers. Foreign investors cannot own or operate retail pharmacies, even through Syrian partners who are not licensed pharmacists.
3. Licensing & Registration Process
Establishing a pharmaceutical company in Syria requires coordination across multiple government bodies, with the Ministry of Health serving as the primary regulator for drug manufacturing and registration.
Key Government Bodies
| Authority | Role |
|---|---|
| Ministry of Health | Primary regulator; drug registration and pharmaceutical company licensing |
| Directorate of Pharmaceutical Affairs | Drug registration, pharmaceutical company licensing |
| Syrian Investment Agency (SIA) | Administers Investment Law incentives; launched 17 pharmaceutical projects (2017-2020) worth SYP 16 billion |
| Ministry of Economy and Trade | Trade licenses; drug pricing coordination |
| Ministry of Industry | Manufacturing licenses |
Drug Manufacturing Facility Licensing (12-24 Months)
- Investment Approval
Submit application to Syrian Investment Agency under Investment Law 18/2021 with business plan, technical specifications, and financial projections to qualify for tax exemptions - Manufacturing License Application
Submit company registration certificate, site plans complying with WHO GMP standards, Environmental Impact Assessment (mandatory under Syrian Environmental Law), quality assurance documentation, and organizational chart with qualified technical staff - Site Construction
Design and build facilities according to WHO and international GMP conditions, implement ISO 9001 (quality management) and ISO 14001 (environmental management) systems - GMP Certification
Submit GMP documentation to Ministry of Health, undergo facility inspection by MoH inspectors, obtain GMP approval certificate - Manufacturing License Issuance
Final inspection and approval; license issued by Ministry of Industry in coordination with Ministry of Health - Drug Registration
Register individual pharmaceutical products with Directorate of Pharmaceutical Affairs for market authorization
Drug Import Licensing Requirements
Required Documentation for Drug Imports
- Certificate of Pharmaceutical Product (CPP) from country of origin
- Valid GMP certificate
- Certificate of Analysis for recently released batch (not more than 1 year old)
- Registration certificate from country of origin
- Package insert/patient information leaflet
- All documents must be legalized by Chamber of Commerce and Syrian Embassy in country of origin
Medical Device Registration
Documents must be legalized by Chamber of Commerce and Syrian Embassy in country of origin. Required submissions include:
- Manufacturer's company registration
- CE mark or US FDA certificate
- Certificate of Free Sale
- QMS certificate (ISO 13485 required)
- Testing reports
Important Medical Device Restrictions
- Import of refurbished medical equipment is prohibited
- A local authorized representative is required
- Timeline: approximately 1 month for company registration plus testing time
4. Investment Requirements & Capital
Minimum Capital Requirements
| Company Type | Minimum Capital | Notes |
|---|---|---|
| Foreign Company Branch | SYP 10,000,000 (~$700-900) | Currency has depreciated significantly |
| Pharmaceutical Manufacturing LLC | Determined by MoH/SIA | Based on project scope |
| Investment License (Damascus) | $1,000,000 | Major cities threshold |
| Investment License (Rural) | $400,000 | Rural areas threshold |
| Investment License (Eastern) | $200,000 | Deir ez-Zor, Hasakah, Raqqa |
Registration Requirements for Foreign Investors
- Investor passport/ID and legal power of attorney
- Economic and technical feasibility study
- Proof of property/land for project
- All foreign documents must be legalized by Foreign Ministry of origin country
- Attested by Syrian embassy/consulate
- Approved by Syrian Ministry of Foreign Affairs
- Security clearance (1-3 months processing)
Processing time: 6-10 weeks for standard applications through the one-stop window system.
Tax Rates (Without Exemptions)
Corporate Tax Structure
Base rate: 22% | Effective rate: ~30% (including reconstruction tax)
Qualified pharmaceutical projects may claim 50-75% exemptions under Investment Law 18/2021
Development area projects receive 75% income tax reduction for 10 years
5. Market Opportunities & Sector Analysis
Pre-War Market Status (Pre-2011)
Syria's pharmaceutical industry was among the most developed in the Arab world before the conflict.
| Metric | Pre-War Value |
|---|---|
| Total Pharmaceutical Production | ~$600 million annually |
| Local Market Consumption | >$400 million |
| Export Value | ~$150 million/year to 52 Arab countries |
| Regional Ranking | 2nd place in Arab world pharmaceutical production |
| Pharmaceutical Factories | 63 factories producing 5,700 product types |
| Local Market Coverage | ~90% of local needs |
| Employment | ~17,000 workers (85% women, 25% university graduates) |
Current Market Status (2024-2025)
- Pharmaceutical imports (2023): $86.19 million (UNCTAD data)
- Active factories: ~70 operational; 10 stopped due to damage; 20 licensed factories under construction
- Manufacturing capacity claims: ~90% local coverage maintained
- International licensing: 58+ international companies granted manufacturing licenses for ~390 products
Major Domestic Manufacturers
| Company | Location | Key Information |
|---|---|---|
| Thameco (Arabian Medical Company) | Damascus | Largest state-owned; azithromycin, acetaminophen, vitamin C |
| Aleppo Pharmaceutical Industries (ALPHA) | Aleppo | 1,000 employees; licensed from Bristol-Myers Squibb, Medinova |
| ELSaad Pharmaceuticals | Syria | 200+ representatives; 110+ products; leader in antibiotics |
| Asia Pharmaceutical Industries | Aleppo | GMP-certified manufacturer and distributor |
| Razi Pharmaceutical Industries | Aleppo | Group of factories established 1986 |
Critical Drug Shortages - Investment Opportunities
Severe Shortage Categories
| Cancer Drugs | Severe shortage; only 3 oncologists serve 5.1 million people in NW Syria |
| Biologics/Biosimilars | No local production capacity - greenfield opportunity |
| Insulin | Severe shortage; ~400,000 Syrians depend on insulin |
| Dialysis Supplies | Critical; hospitals cannot purchase machines |
| APIs | 100% imported - identified as key weakness |
Healthcare Infrastructure Status
| Metric | Status (2025) |
|---|---|
| Hospitals Fully Functional | 57-58% (WHO) |
| Primary Healthcare Centers Operational | 23-37% |
| Healthcare Workforce Departed | 50-70% |
| Infrastructure Destroyed | ~40% |
| WHO Funding Gap | 81% |
Priority Investment Opportunities
- API Manufacturing
Syria imports 100% of Active Pharmaceutical Ingredients. ~70 operational factories require supply. Local API production would substantially improve supply chain resilience. - Oncology Products and Equipment
Al-Biruni Hospital (treats 70% of Syria's cancer patients) has non-functional CT scanners. Critical shortage of cancer treatment drugs and equipment. - Medical Equipment Supply
Immediate needs: CT/MRI scanners, ventilators, dialysis machines, linear accelerators, laboratory equipment, oxygen concentrators. Equipment outdated by a decade. - Biologics and Biosimilars
No local production capacity. Greenfield opportunity for technology transfer partnerships. - Healthcare Infrastructure
Hospital rehabilitation (42% non-functional), primary care center rebuilding (77% not fully operational), medical training programs.
Investment Agreements Signed (2025)
- $14 billion from Qatar, UAE, Italy, and Türkiye (August 2025)
- $6.4 billion in 47 MoUs from Saudi companies (July 2025)
- New bilateral investment treaty signed with Saudi Arabia in 2025
6. Sanctions Status & Due Diligence (2025-2026)
The sanctions landscape transformed dramatically in 2025 following Syria's December 2024 political transition.
US Sanctions Removal Timeline
| Date | Action |
|---|---|
| May 23, 2025 | General License 25 effectively lifts all restrictions; 180-day Caesar Act waiver |
| July 1, 2025 | US comprehensive sanctions officially ended via Executive Order 14312 |
| July 8, 2025 | HTS Foreign Terrorist Organization designation revoked |
| September 2, 2025 | BIS Final Rule relaxes export controls; EAR99 items authorized |
| December 18, 2025 | Caesar Act permanently repealed as part of NDAA FY2026 |
EU Sanctions Status
- EU suspended sanctions on energy and transport sectors (February 2025)
- Removed asset freezes on four major banks
- Most autonomous sanctions lifted by May 2025
- Important: EU sanctions never prohibited export of food, medicines, or medical equipment to Syria
Post-Sanctions Pharmaceutical Environment
What Changed for Pharma Investors
- No specific OFAC license now required to send US-origin medicine to Syria
- Financial transactions can flow through Syrian banks
- Commercial Bank of Syria can maintain correspondent accounts with US institutions
- Banking relationships for humanitarian/reconstruction purposes permitted
Remaining Due Diligence Requirements
Compliance Considerations
- SDN designations remain for Bashar al-Assad and associates, human rights abusers, Captagon traffickers, ISIS/Al-Qa'ida affiliates
- Syria remains on State Sponsor of Terrorism list
- PAARSS program maintains 139 redesignated individuals
- SWIFT reconnection still in progress
- Over-compliance ("de-risking") by international banks persists
- Enhanced due diligence recommended
Last updated: January 12, 2026. Information subject to change as Syria's regulatory environment continues to evolve.