Syria’s Real Estate Market Between the “No Objection” Document and Prevailing Value Assessments

The issuance of Circular No. 135 by the Ministry of Finance on July 30, 2025 has affected the regulatory framework of Syria’s real estate market, as it redefined the basis for calculating real estate sales tax and linked the completion of property transfers to obtaining a “No Objection to Completing the Real Estate Transaction” document.

The Ministry of Finance issued Circular No. 135 in July 2025, which reduced the prevailing values adopted by the finance directorates to 30 per cent of the values previously set. That is, a property whose prevailing value had been estimated by the finance directorate at SYP 1 billion is now calculated for tax purposes on the basis of only SYP 300 million. Accordingly, the base on which the tax is calculated — that is, the value to which the percentage specified in the law is applied — has shrunk by 70 per cent compared with the previous administrative estimate.

The tax equals the legal percentage multiplied by the prevailing value adopted by the Ministry of Finance. So, if that legal percentage is one per cent and the adopted prevailing value is SYP 300 million, then the tax is SYP 3 million. Therefore, reducing the prevailing value to 30 per cent means reducing the tax base itself, not amending the legal tax rate.

Real Estate Sales Law No. 15 of 2021 had set the sales tax at one per cent on ready residential properties, to be calculated from the “prevailing value” adopted by the Ministry of Finance, not from the price stated in the sale contract between seller and buyer. When the law was approved, this shift was presented as a means of achieving tax justice and preventing sales from being registered at prices lower than the real price. The law stipulated the adoption of a three-tier valuation structure, including sub-committees in administrative units, main committees in the finance directorates, and a central committee chaired by the Minister of Finance, which was supposed to ensure an estimate close to the prevailing market price. However, practical application has shown that the estimate is made based on valuation maps adopted by the finance directorates, without any reliance on a systematic on-site inspection or detailed market data.

The latest reduction under Ministry of Finance Circular No. 135 did not affect the mechanism for determining the prevailing value itself, but was limited to the percentage used to calculate it. Thus, the core problem remains, namely that the tax is imposed on an administrative estimated value that may not match the actual prevailing price at which the sale takes place in the market.

Despite reducing the prevailing value to 30 percent of previous estimates, criticism is growing over the valuation mechanism itself. Some taxpayers whom The Syria Report interviewed at the Damascus Finance Directorate said that the problem lies not only in the calculation percentage, but in the basis on which the estimated value is built. Zahir, who owns a residential property in the New Zahera area, said that the market value of his property is close to SYP 1 billion, yet the finance directorate estimated it at SYP 1.2 billion —an increase of SYP 200 million over the actual price at which the sale was conducted. Although the buyer paid only SYP 1 billion, the tax that Zaher must pay is calculated according to the higher estimated value adopted by the finance authorities.

Rafd, who owns a property in the RuknEddin area, questioned the mechanism used in the valuation, pointing to the absence of expert committees carrying out field inspections, and said that the estimate is made by employees in offices, without ground visits. In his view, the property cannot be sold at the price determined by the finance directorate if it exceeds the price actually being used in the market.

Real estate expert Ammar Youssef said that there is clear disorder in the valuation process and that it does not reflect the true value of properties on the ground. He noted that the mechanism in place since the issuance of Law No. 15 has not changed, as the estimate is carried out by employees in the finance directorates according to administrative estimates, not by specialised real estate valuation experts. Mr Youssef called for the formation of committees of specialist real estate experts to revalue properties in line with market prices. Continuing to rely on the current mechanism, he said, causes injustice to property owners. He also questioned the reasons for the finance directorates’ persistence with the same method of estimation despite repeated criticism.

Accordingly, it appears that lowering the percentage used to calculate the prevailing value did not address the essence of the problem, as the gap remained between the actual prevailing market price and the estimated value adopted for tax purposes, which directly affects the cost of sale and the confidence of those dealing in the real estate market.

Alongside the debate over valuation, the “No Objection to Completing the Real Estate Transaction” document still constitutes an additional obstacle to completing sales and transferring ownership. Obtaining this document is considered a condition within the financial clearance procedure, which is required before registering the sale or transferring ownership. The financial clearance procedure is completed at the finance directorate in the governorate where the property is located, where the concerned party submits an application that includes a real estate registration statement and the sale contract. After reviewing the tax status and ensuring there are no dues or legal impediments such as seizure notices or a restraint on disposal in the real estate record, the directorate issues the financial clearance document and, in parallel, the “No Objection to Completing the Real Estate Transaction” document, to complete the transfer of ownership in the Land Registry.

However, some applicants reported that the procedures for obtaining the document may go beyond the financial aspect to include referrals to Internal Security and vetting procedures that may extend for long periods. Amer, one applicant, told The Syria Report that he submitted an application to obtain the “No Objection” document, and after reviewing the data he was asked to refer to Internal Security because his father was an officer under the Assad regime, even though his father was discharged in 1990. He explained that since 10 days ago, the “study” is still ongoing and he has not obtained the document.

Likewise, Khaled, another applicant at the Damascus Finance Directorate, said that he submitted an application to obtain the document three months ago and has not received it to date, because of what he described as a study by Internal Security that has not yet been completed. He considered that this document has become one of the forms of security approvals.

By contrast, a source in the Damascus Finance Directorate told The Syria Report that the “No Objection to Completing the Real Estate Transaction” document is issued on the same day by the Ministry of Finance. Anyone with a legal issue is referred to Internal Security to resolve that issue, the source said, adding that the finance directorates are not concerned with security procedures.

According to Ministry of Finance Circular No. 135 issued this past July, the “No Objection” document came in the context of resuming the issuance of financial clearance after it had stopped since December 2024, in coordination with the Ministries of Interior and Local Administration. Circular No 135 was a continuation of Circular No. 87 issued on June 21, 2025, which allowed the granting of the financial clearance document to those wishing to transfer their real estate ownership through assignment or direct relinquishment in the Land Registry, after its issuance had stopped since December 2024. This shows that the resumption of ownership transfer transactions took place gradually through successive circulars to reactivate the real estate market after a period of freeze.

Circular No. 135 made the document valid for only three months, and it is granted in parallel with financial clearance, after coordination with the General Commission for Taxes and Fees and the Directorate of Cadastral Affairs to ensure there are no seizure notices or a ban on disposal. The circular also referred to coordination with what is known as the “Security Approvals Platform” to verify that there are no security reasons preventing the owner from disposing of their property. This platform is not available to the public, and is used by employees of government bodies to verify that there are no security impediments when carrying out a real estate transaction. Accordingly, the “No Objection” document replaced the direct security approval that had previously been imposed, but in a new administrative form.

There is no explicit legal text requiring the obtaining of the “No Objection” document to complete a real estate transaction, as the registration condition set out in the Real Estate Sales Law relates to obtaining financial clearance. However, the administrative circular in practice linked financial clearance and the “No Objection” document, making the latter an effective requirement for completing the transfer of ownership.

Thus, a document that is supposed to be a financial procedure linked to financial clearance becomes a point of intersection between the financial administration and the security bodies, whether through institutional coordination or through individual referrals to Internal Security, which leads to delaying the completion of sale and ownership transfer transactions and adds a new procedural burden to the real estate market.