Standard CIT rate — 15%

The standard corporate income tax rate in Uzbekistan is 15% — applicable to most Uzbek legal entities and foreign legal entities operating through a permanent establishment in Uzbekistan. CIT is levied on taxable profit — gross income less deductible expenses as defined by the Tax Code. Presidential Decree No. UP-229 dated 28 December 2024 confirmed that CIT and VAT rates will remain unchanged until 1 January 2028 — providing investors with meaningful rate stability during the investment horizon.

Sector-specific CIT rates

The following sector-specific CIT rates apply under the Tax Code: 20% — commercial banks, producers of cement (clinker) and polyethylene granules, mobile services providers, and operators of markets and shopping malls; 1% — businesses producing knitwear, footwear, and leather goods (from 1 January 2025 to 1 January 2028, subject to conditions); 50% reduction — entities in the electrical industry where at least 80% of revenue derives from electrical product sales (until 1 January 2027). Bond Stone verifies the applicable sector rate at the outset of every investment structuring mandate.

IT Tech Park — CIT exemption until 2028

Residents of the Uzbekistan IT Tech Park — established by Presidential Decree No. UP-5099 dated 30 June 2017 — are entitled to income tax exemption until 2028. From 1 February 2025 to 1 January 2030, foreign non-resident companies providing export IT services to IT Tech Park residents exceeding USD 10 million per year are also exempt from CIT on those IT export service revenues. Bond Stone advises on IT Tech Park residency eligibility and CIT exemption scope.

SEZ CIT exemptions

Residents of Uzbekistan’s 28 Special Economic Zones are entitled to CIT exemptions for the duration of their SEZ residency under the SEZ operating conditions. The specific CIT exemption period and scope depends on the SEZ, the investor’s qualifying activity, and minimum investment threshold. Bond Stone advises on SEZ-specific CIT exemption terms and on structuring the SEZ investment to maximise the CIT benefit.

Deductible expenses — key items

Deductible expenses for CIT purposes include: business expenses incurred in generating taxable income; Note: a 50% CIT rate reduction applies to taxpayers switching to the CIT regime from the simplified turnover tax for the first time after 1 September 2022 (for the tax period of switching, provided turnover does not exceed UZS 10 billion), and to CIT payers whose revenue exceeds UZS 10 billion for the first time (for that period and the following one, provided revenue does not exceed UZS 100 billion) — depreciation on fixed assets at rates prescribed by the Tax Code; salary costs and social tax; interest on borrowings (subject to transfer pricing limits on related-party debt); and professional fees. Non-deductible items include dividends paid to shareholders, penalties and fines, and expenses without supporting documentation. Bond Stone advises on expense deductibility in the context of intercompany structuring mandates.

Permanent establishment — non-residents

Foreign companies conducting business activities in Uzbekistan without a registered entity may create a permanent establishment (PE) — triggering CIT liability in Uzbekistan on profits attributable to the PE. The PE risk threshold and profit attribution rules follow OECD guidelines as adapted in the Uzbek Tax Code. Bond Stone advises foreign companies on PE risk assessment and on structuring activities to manage PE exposure in Uzbekistan.

CIT Structuring — Manufacturing SEZ

CIT · Uzbekistan · Manufacturing · SEZ

Advising a foreign manufacturer on CIT structuring through an Uzbek SEZ entity — SEZ CIT exemption scope, qualifying activity compliance, separate accounting requirements, and interaction between the SEZ exemption and the standard 15% CIT regime.

IT Tech Park — CIT Exemption

CIT · Uzbekistan · Technology

Advising an IT company on IT Tech Park residency to access the income tax exemption until 2028 — eligibility assessment, exempt activity scope, and ongoing compliance with IT Tech Park operating conditions.

Sector Rate Analysis — Manufacturing

CIT · Uzbekistan · Manufacturing

Advising a foreign manufacturer on the applicable CIT rate for its Uzbek entity — confirming the standard 15% rate applies and identifying any sector-specific rates or incentives available for the specific manufacturing activity.

PE Risk Assessment — Services

CIT · Uzbekistan · Corporate

Advising a foreign services company on PE risk arising from its activities in Uzbekistan — PE threshold analysis under the applicable DTT, profit attribution methodology, and structuring recommendations to manage PE exposure.

CIT Deductibility — Intercompany Fees

CIT · Uzbekistan · Corporate

Advising on CIT deductibility of management fees and technical services paid to a foreign parent — arm’s length analysis, documentation requirements, and WHT on service fee payments to the foreign parent entity.

Investment Contract — CIT Stability

CIT · Uzbekistan · Investment

Advising a foreign investor on obtaining an investment agreement with the government of Uzbekistan — CIT rate stability guarantee, qualifying investment threshold, and ongoing compliance with investment agreement conditions.