Opening a healthcare business in Cambodia

TL;DR

• Opening a healthcare business in Cambodia means two doors to clear: first a company registered with the Ministry of Commerce (MoC), then a sector licence from the Ministry of Health (MoH) specific to the medical activity (clinic, polyclinic, hospital, dental practice, consultation room).
• Foreign investment is allowed, but practitioners must be licensed: every doctor must be registered with the Medical Council of Cambodia (MCC) and hold a practitioner licence. A pharmacy requires the presence of a qualified pharmacist — and the pharmacist’s Khmer nationality is a constraint to be confirmed (see below).
• Medical and hospital services are non-taxable supplies for VAT (GDT source): no VAT charged to the patient, but no recovery of input VAT. Patent tax and corporate income tax (ToI) apply as usual.

Sector overview

Private clinics and pharmacies are very common in Cambodia, especially in Phnom Penh and Siem Reap, driven by strong demand (a population poorly covered by the public system, expatriates, nearby medical tourism). But the sector is heavily regulated — one of the most controlled in the country. Five main formats:

• Consultation room: outpatient consultations only, no inpatient beds.
• Clinic: small structure with inpatient beds (limited capacity).
• Polyclinic: mid-size structure, several specialties and inpatient beds.
• Private hospital: large capacity, full technical platform.
• Separately: dental practice, laboratory, pharmacy (specific regime, see below).

The distinction between these formats rests in part on the number of inpatient beds — a criterion the MoH regulation uses to classify the establishment and set its obligations. The exact bed count per category should be confirmed with the MoH when filing, as it drives the type of licence.

Step 1 — Set up the company (general setup)

Like any commercial activity in Cambodia, a private health establishment must first exist as a company registered with the MoC:

• The Co. Ltd. (Private Limited Company) is the standard. Cambodia allows 100% foreign capital in most activities, except land ownership (reserved for Cambodians, hence the commercial lease for the premises). See setting up a company.
• To choose between Co. Ltd., single-member company, branch, etc., see the business structures comparison.

General foreign-eligibility rules are published on the OBR / registrationservices.gov.kh portal. This step follows the standard procedure (registration via the single portal, tax registration with the GDT, annual patent tax). What makes a healthcare project different is Step 2.

Step 2 — The Ministry of Health sector licence

The MoH is the authority responsible for the opening, control and closing of private health establishments. Medical, paramedical and medical-aid establishments are governed by a dedicated law (Law on Management of Private Medical, Paramedical and Medical Aid Profession). The MoH has even ordered the systematic checking of licences of all clinics and polyclinics.

a) Opening licence for a medical / paramedical establishment

• File an opening application with the MoH (the relevant department depends on the type: hospital, polyclinic, clinic, consultation room, dental practice).
• Conditions: adequate medical equipment, technical and ethical standards, compliant premises, qualified staff.
• The licence is renewable and triggers inspections.

b) Registration of health professionals with their council

In Cambodia, five professional councils assist the MoH in supervising practitioners: the Medical Council of Cambodia (doctors), the Pharmaceutical Council, the Dental Council, the Council of Nurses and the Midwives Council.

• Every doctor must be registered with the Medical Council of Cambodia (MCC) and hold a valid practitioner licence to examine patients, treat diseases or open a clinic. The MCC is an autonomous body established by Royal Decree in February 2000.
• The MCC provides separate registration pathways for Cambodian and foreign practitioners. A foreign doctor must therefore register with the MCC on top of obtaining an EB visa and a work permit.
• Dentists fall under the Dental Council, nurses under the Council of Nurses, etc. — the same mandatory-registration logic.

c) Pharmacy: a specific regime

Opening a pharmacy (a pharmaceutical-selling establishment) falls under the Law on the Management of Pharmaceuticals and its implementing Prakas, supervised by the MoH’s Department of Drugs and Food (DDF):

• The regulation requires the presence of a qualified pharmacist (a diploma recognised by the MoH) in each pharmacy; in their absence, a qualified replacement must be arranged.
• Per legal analyses of the pharmaceutical law, the pharmacist must be a Khmer national, with a limit of one pharmacy per pharmacist licence. To be confirmed with the DDF / the Pharmaceutical Council: this point heavily shapes a foreign-capital project (a foreign investor may fund the pharmacy, but the responsible pharmacist must meet these conditions).
• Opening, closing or relocating a pharmaceutical-selling establishment follows a dedicated procedure (formalities and conditions set by Prakas).

d) Importing pharmaceuticals

If your project imports medicines or therapeutic products, this runs through the DDF and the CamPORS system (Cambodia Pharmaceutical Online Registration System, launched in 2019):

• Every therapeutic product must be registered with the DDF before marketing.
• Operating a pharmaceutical import/export establishment requires MoH authorisation.
• Product registration may only be done by a pharmaceutical manufacturer or a pharmacist.

Tax angle

Once the company is set up and the establishment licensed, tax follows the general rules, with one major VAT specificity:

• VAT — health services are NON-taxable supplies. The GDT classes hospital, clinic, medical and dental services, plus the sale of medical and dental goods incidental to those services, among non-taxable supplies; medicines supplied to patients are not subject to VAT either. Crucial consequence: an establishment making non-taxable supplies charges no VAT to the patient but cannot recover the VAT paid on its purchases (equipment, fit-out, supplies), even with a valid invoice. See the VAT guide.
• Patent tax (annual business tax): due from registration, as for any company. See the patent tax guide.
• Corporate income tax (ToI): 20% of profit (or a 1% minimum tax on turnover), filed annually.
• Salary tax (ToS): withheld on the salaries of doctors, nurses and staff. See business structures.
• Investment incentives (QIP): depending on the project, QIP status may grant exemptions — not automatic for healthcare, to be checked with the MEF / CDC before structuring.

Foreign practitioners: visa, permit and council registration

A health establishment often employs foreign practitioners. Each needs three cumulative things:

1. An EB visa + a work permit tied to your company — the same procedure as for any foreign employee, see the work permit guide.
2. Registration with their professional council (MCC for doctors, Dental Council for dentists, etc.).
3. A valid practitioner licence.

Build these lead times and costs into your recruitment plan: a foreign doctor who has the visa but not the MCC registration cannot see patients.

Common pitfalls

FAQ

Can a foreigner own a clinic 100% in Cambodia?

On the capital side, yes in most cases: Cambodia allows 100% foreign capital via a Co. Ltd., except for land ownership (hence the lease). But the right to practise medicine attaches to licensed practitioners (MCC-registered), not to the shareholder. You can own the clinic without being a doctor, provided you employ registered practitioners.

Which authorisations are needed on top of the company?

At a minimum: the establishment opening licence issued by the Ministry of Health (MoH), and the registration of each practitioner with their professional council (Medical Council of Cambodia for doctors, Dental Council for dentists, etc.) with a valid practitioner licence.

Do I need a Cambodian pharmacist to open a pharmacy?

The pharmaceutical law requires the presence of a qualified pharmacist in each pharmacy. The commonly reported rule adds that the pharmacist must be a Khmer national, with one pharmacy per licence — a point we present cautiously and that should be confirmed with the Department of Drugs and Food (DDF) or the Pharmaceutical Council before investing. In practice, this often pushes founders to partner with a Cambodian pharmacist.

Are medical services subject to VAT?

No: the GDT classes hospital, clinic, medical and dental services (and medicines supplied to patients) among non-taxable supplies. No VAT charged to the patient — but no recovery of input VAT on your purchases. See the VAT guide.

How do I import medicines for my clinic or pharmacy?

Through the MoH’s Department of Drugs and Food (DDF) and the CamPORS system: every therapeutic product must be registered before marketing, and pharmaceutical import/export requires MoH authorisation. Registration goes through a manufacturer or a pharmacist. Source only from registered importers.

How long does it take to open, in total?

The company is set up in a few weeks via the single portal. The limiting factor is the MoH licence (file, premises compliance, equipment) and the registration of practitioners with their council: expect several months. For a pharmacy, the responsible pharmacist is the critical prerequisite. Plan around the health step, not the company step.