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 is stable until 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 55 double taxation treaties. 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 CIT exemption until 2030 for foreign non-resident IT companies providing export IT services exceeding USD 10 million 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. Dividends from JSC shares are exempt from WHT until 31 December 2028.

55 bilateral double taxation treaties

Uzbekistan has concluded double taxation treaties with 55 states — including China, Germany, France, Russia, UAE, UK, and USA. 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 EY has flagged that in some cases the DTT rate may be higher than expected. Bond Stone advises on treaty-specific royalty rates before any IP licence arrangement is entered into with an Uzbek counterpart.

JSC dividend exemption — until 31 December 2028

Dividends paid from shares in Uzbek joint stock companies are exempt from WHT for both resident and non-resident recipients until 31 December 2028. This exemption makes JSC structuring particularly attractive for investors seeking to repatriate profits without WHT during the exemption period. Bond Stone advises on JSC vs OOO structuring in the context of investor profit repatriation planning.

Automatic DTT application — no withholding required

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 duly apostilled tax residency certificate from its home state competent authority. The Uzbek payer applies the treaty rate automatically — no advance ruling from the Uzbek tax authority is required. Bond Stone advises on the documentation package required for compliant treaty application at source.

DTT Planning — Chinese Manufacturing JV

Tax Advisory · Uzbekistan · China

Advising a Chinese manufacturing JV on dividend WHT planning — China-Uzbekistan DTT analysis, residency certificate requirements, reduced WHT rate application, and coordination with Chinese tax advisers on the PRC treatment of Uzbek-source dividends.

JSC Structuring — WHT Exemption

Tax Advisory · Uzbekistan · Corporate

Advising a foreign investor on structuring its Uzbek investment through a JSC to access the dividend WHT exemption until 31 December 2028 — JSC formation, share structure, and profit distribution mechanics to maximise the WHT exemption benefit.

IT Tech Park — Tax Incentive Structure

Tax Advisory · Uzbekistan · Technology

Advising a foreign IT company on IT Tech Park residency to access the income tax exemption until 2028 — eligibility assessment, CIT and VAT exemption scope, social tax exemption for foreign IT specialists, and ongoing compliance with IT Tech Park operating conditions.

Royalty WHT — IP Licence Advisory

Tax Advisory · Uzbekistan · IP

Advising on WHT on royalty payments from an Uzbek licensee to a foreign licensor — 20% domestic rate analysis, applicable DTT rate (5–10% for most treaty partners), residency certificate requirements, and transfer pricing compliance for the licence fee.

Transfer Pricing — Management Fees

Tax Advisory · Uzbekistan · Corporate

Advising on structuring management fee payments from an Uzbek subsidiary to its foreign parent — arm’s length fee determination, documentation requirements, WHT on service fees, and CIT deductibility assessment under the Uzbek Tax Code.

SEZ Tax Structure — Manufacturing

Tax Advisory · Uzbekistan · Manufacturing · SEZ

Advising a foreign manufacturer on the tax structure for an Uzbek SEZ investment — CIT exemption scope, VAT treatment of goods within the SEZ, customs duty relief on imported equipment, and interaction between SEZ tax benefits and the standard Uzbek Tax Code regime.