Tax Advisory in Uzbekistan

Corporate Income Tax Structuring

Advising on the CIT position of foreign-invested Uzbek entities — standard 15% rate, reduced rates for qualifying sectors, SEZ and IT Tech Park exemptions, and structuring investment activity to optimise the CIT position. The CIT rate will not be increased before 1 January 2028 under Presidential Decree No. UP-229.

Withholding Tax & DTT Planning

Advising on WHT on dividends (10% to non-residents), interest (10%), and royalties (20%) paid to foreign shareholders — and on reducing these rates through Uzbekistan's 54 double taxation treaties in force. Treaty access requires a tax residency certificate from the recipient's home state competent authority.

Transfer Pricing

Advising on Uzbekistan's transfer pricing rules applicable to controlled transactions between an Uzbek subsidiary and its foreign parent — arm's length principle, documentation requirements, and intercompany structuring for management fees, royalties, and loans to withstand Uzbek tax authority scrutiny.

VAT — Investment Transactions

Advising on VAT implications for foreign investors — 12% standard rate, import VAT on goods brought into Uzbekistan, VAT on services received from foreign suppliers (reverse charge), and VAT exemptions applicable to specific investment transactions and SEZ goods flows.

SEZ & IT Tech Park Tax Incentives

Advising on CIT and VAT exemptions available to SEZ residents and IT Tech Park participants — including the income tax exemption until 2028 for IT Tech Park residents, and the exemption until 2030 for non-resident companies (other than tax residents of treaty states) with export services above USD 10 million a year, on IT services to IT Tech Park residents.

Profit Repatriation Tax Planning

Advising on the tax-efficient repatriation of profits from Uzbekistan — dividend WHT optimisation through the DTT network, structuring the holding layer to access beneficial treaty rates, and the documentation required to apply reduced treaty WHT rates at source. Until 31 December 2028, dividends on JSC shares are exempt for individuals and taxed at 5% for non-resident companies (Tax Code, Art. 483).

55 bilateral double taxation treaties

The Tax Committee reports 54 double taxation treaties in force (6 March 2026). DTTs reduce WHT on dividends (typically to 5–10%), interest (typically to 5–10%), and royalties (typically to 5–10%, compared to the domestic 20% rate). Treaty access requires a tax residency certificate issued by the competent authority of the recipient's home state. Bond Stone advises on treaty applicability and the documentation required for compliant treaty access.

Royalty WHT — DTT planning is critical

Uzbekistan's domestic WHT rate on royalties (20%) is higher than the rate in most DTTs (typically 5–10%). This means treaty access is particularly valuable for royalty payments — but check each treaty, as relief varies. Bond Stone advises on treaty-specific royalty rates before any IP licence arrangement is entered into with an Uzbek counterpart.

JSC dividend relief — until 31 December 2028

Until 31 December 2028, dividends on shares of a joint-stock company are exempt for individuals, resident and non-resident, and taxed at 5% for non-resident companies, against the standard 10% (Tax Code, Art. 483). There is no 0% rate for companies. For a foreign corporate investor, the benefit over an LLC is the 5% rate, not an exemption. Bond Stone advises on JSC vs LLC structuring in the context of investor profit repatriation planning.

Treaty relief at source

Under the Uzbek Tax Code, income subject to WHT may be paid to a treaty-resident without withholding (or at the reduced treaty rate) if the recipient provides a tax residency certificate meeting Article 358 of the Tax Code: legalised or apostilled, unless published on the foreign authority's website. The Uzbek payer applies the treaty rate itself — no advance ruling from the Uzbek tax authority is required. Bond Stone advises on the documentation package required for compliant treaty application at source.