Withholding Tax & DTT in Uzbekistan

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%; insurance premiums — 10%; international telecommunications and freight — 6%; royalties and other Uzbek-source income — 20% (Art. 353). 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 relief — 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, and a treaty may already give the same rate. Bond Stone advises on choosing between a JSC and an LLC for the investment.

Uzbekistan's DTT network — 54 treaties in force

The Tax Committee reports 54 double taxation treaties in force (6 March 2026). 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, legalised or apostilled unless published on that authority's website (Art. 358). Bond Stone advises on treaty-specific rates and the documentation required for compliant treaty access.

Treaty relief at source

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 tax residency certificate meeting Article 358. Bond Stone advises on the documentation package required for treaty relief at source.

Royalty WHT — critical planning area

The domestic 20% royalty WHT rate is higher than the rates in most of Uzbekistan's DTTs. Rates vary by treaty, so check the specific treaty before any IP licence 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.