Transfer pricing framework — Uzbekistan

Uzbekistan’s transfer pricing rules are embedded in the Tax Code and require that transactions between related parties be priced on arm’s length terms — as if conducted between independent parties in comparable circumstances. The Uzbek transfer pricing framework is broadly consistent with OECD Transfer Pricing Guidelines, though local documentation requirements and audit practices have specific features. The retention period for transfer pricing documentation was reduced from 5 to 3 years from 2024 under recent Tax Code amendments.

Controlled transactions — scope

Uzbek transfer pricing rules apply to: transactions between an Uzbek entity and its foreign affiliates; transactions with entities in preferential tax jurisdictions (a list maintained by the Uzbek Ministry of Finance); and transactions that the tax authority determines are structured to shift profit out of Uzbekistan. Management fees, technical services, royalties, intercompany loans, and goods supply between related parties are all subject to transfer pricing scrutiny. The Uzbek tax authority has increased its focus on transfer pricing audits in recent years.

Transfer pricing methods

The Uzbek Tax Code recognises the following methods for determining the arm’s length price: Comparable Uncontrolled Price (CUP); Resale Price Method; Cost Plus Method; Transactional Net Margin Method (TNMM); and Profit Split Method. The most appropriate method depends on the nature of the transaction and the availability of comparable data. Bond Stone advises on method selection and coordinates with the client’s transfer pricing specialists on the economic analysis.

Documentation requirements

Uzbek taxpayers conducting controlled transactions above the materiality threshold are required to maintain transfer pricing documentation demonstrating arm’s length pricing. The documentation must be available for submission to the Uzbek State Tax Committee on request. From 2024, the mandatory retention period is 3 years. Bond Stone advises on Uzbek documentation requirements and coordinates with the multinational group’s global transfer pricing policy to ensure local compliance.

Management fees and technical services

Management fees and technical services paid to foreign parent companies are among the most scrutinised intercompany transactions in Uzbekistan. The Uzbek tax authority examines whether the services were actually provided, whether the fee is arm’s length, and whether the deduction is supported by appropriate documentation. Bond Stone advises on structuring and documenting management service arrangements to satisfy Uzbek tax authority requirements.

Preferential jurisdiction transactions

Transactions with entities in jurisdictions on Uzbekistan’s preferential (low-tax) jurisdictions list are subject to enhanced transfer pricing scrutiny regardless of whether the counterparty is a related party. Bond Stone advises on identifying whether a counterparty’s jurisdiction is on the Uzbek list and on the enhanced documentation obligations that apply to such transactions.

Management Fee Structure

Transfer Pricing · Uzbekistan · Corporate

Advising on structuring management fee payments from an Uzbek subsidiary to its foreign parent — arm’s length fee determination, service documentation (service agreement, evidence of delivery), WHT on fee payments, and CIT deductibility.

Royalty — IP Licence Pricing

Transfer Pricing · Uzbekistan · IP

Advising on transfer pricing for a royalty payment under an IP licence from a foreign group entity to an Uzbek licensee — arm’s length royalty rate (domestic WHT 20%, reduced to 5–10% under applicable DTT), TNMM analysis, documentation, and WHT planning.

Intercompany Loan — Arm’s Length Rate

Transfer Pricing · Uzbekistan · Finance

Advising on arm’s length interest rate for an intercompany loan from a foreign parent to an Uzbek subsidiary — comparable uncontrolled price analysis, documentation, WHT on interest (10% domestic rate), and CIT deductibility of interest payments.

Documentation Preparation

Transfer Pricing · Uzbekistan · Compliance

Preparing transfer pricing documentation for a multinational group’s Uzbek subsidiary — local file covering management services, intercompany loans, and goods supply, with 3-year retention period compliance.

Preferential Jurisdiction — Enhanced Scrutiny

Transfer Pricing · Uzbekistan · Corporate

Advising on enhanced transfer pricing documentation obligations for transactions with a counterparty in a jurisdiction on Uzbekistan’s preferential list — documentation requirements and risk mitigation strategy.

Tax Authority Challenge — Response

Transfer Pricing · Uzbekistan · Dispute

Advising an Uzbek subsidiary on responding to a transfer pricing query from the Uzbek State Tax Committee — reviewing the authority’s comparables analysis, preparing a defence, and negotiating the adjustment.