WHT rates — domestic law

Under the Uzbek Tax Code, the following WHT rates apply to payments to non-resident recipients: dividends — 10% (5% for resident recipients); interest — 10%; royalties — 20%; other Uzbek-source income — up to 20% depending on income type. These domestic rates are reduced by applicable double taxation treaties. The 20% royalty WHT rate is notably higher than the rates in most of Uzbekistan’s DTTs (typically 5–10%) — making DTT planning particularly important for IP licensing arrangements.

JSC dividend WHT exemption — 31 December 2028

Dividends paid from shares in Uzbek joint stock companies (JSCs) are exempt from WHT for both resident and non-resident recipients until 31 December 2028. This time-limited exemption makes JSC structuring considerably more tax-efficient than OOO structuring for investors focused on profit repatriation during the exemption period. Bond Stone advises on JSC vs OOO structuring decisions incorporating the WHT exemption benefit and the structural implications of each vehicle.

Uzbekistan’s DTT network — 55 treaties

Uzbekistan has concluded double taxation treaties with 55 states — including China, France, Germany, India, Russia, UAE, UK, and USA. DTTs typically reduce: dividend WHT to 5–10%; interest WHT to 5–10%; and royalty WHT to 5–10% (compared to the domestic 20%). Treaty access requires a tax residency certificate issued by the competent authority of the recipient’s home state — apostilled. Bond Stone advises on treaty-specific rates and the documentation required for compliant treaty access.

Automatic DTT application

Under the Uzbek Tax Code, WHT on payments to non-residents may be withheld at the reduced DTT rate (or not withheld at all) at the time of payment — without requiring advance approval from the Uzbek tax authority — provided the recipient presents a valid apostilled tax residency certificate. This automatic application mechanism reduces administrative burden for compliant treaty access. Bond Stone advises on the documentation package required for compliant automatic DTT application at source.

Royalty WHT — critical planning area

The domestic 20% royalty WHT rate is higher than the rates in most of Uzbekistan’s DTTs. However, EY has noted that for some treaty partners, the DTT royalty rate may in practice equal or exceed the domestic rate — making careful treaty analysis essential before any IP licence arrangement is structured. Bond Stone advises on the applicable treaty royalty rate for specific country combinations before the licence structure is agreed.

Beneficial ownership and anti-abuse

Treaty benefits are available only to the beneficial owner of the income — not to conduit entities that merely pass through payments. The Uzbek tax authority applies beneficial ownership analysis to treaty access claims. Structures where an intermediate holding entity has no substantive economic activity and exists primarily to access treaty benefits are at risk of treaty denial. Bond Stone advises on structuring holding arrangements to satisfy beneficial ownership requirements.

Dividend WHT — Chinese Parent

WHT · Uzbekistan · China

Advising a Chinese parent on dividend WHT planning for an Uzbek manufacturing subsidiary — China-Uzbekistan DTT analysis, residency certificate requirements, applicable treaty rate, and JSC vs OOO structuring to access the 2028 JSC exemption.

JSC Structuring — WHT Exemption

WHT · Uzbekistan · Corporate

Advising a foreign investor on converting its Uzbek OOO to a JSC to access the dividend WHT exemption until 31 December 2028 — conversion procedure, share structure, WHT exemption mechanics, and post-2028 planning.

Royalty WHT — IP Licence

WHT · Uzbekistan · IP

Advising on WHT on royalty payments from an Uzbek licensee to a foreign licensor — 20% domestic rate, applicable DTT rate analysis, residency certificate, and transfer pricing compliance for the royalty rate.

Interest WHT — Shareholder Loan

WHT · Uzbekistan · Finance

Advising on WHT on interest payments on a shareholder loan from a foreign parent to an Uzbek subsidiary — 10% domestic rate, applicable DTT rate, residency certificate, and CIT deductibility of interest.

Beneficial Ownership — UAE Holding

WHT · Uzbekistan · UAE

Advising on structuring a UAE holding company to access the Uzbekistan-UAE DTT for dividend WHT reduction — beneficial ownership substance requirements and documentation to withstand Uzbek tax authority scrutiny.

Treaty Residency Certificate — Documentation

WHT · Uzbekistan · Compliance

Advising on the documentation package required for automatic DTT application at source — apostilled tax residency certificate, beneficial ownership declaration, and record-keeping requirements for the Uzbek paying entity.