GSL / International Taxation / Uzbekistan

Uzbekistan tax system - taxation of Uzbek companies and individuals: VAT, income tax and capital gains. Tax treaties of Uzbekistan .

Service packages Legislation Tax System Audit Services

Taxes of Uzbekistan

15%
Сorporate tax
15%
Capital gains tax
12%
VAT
10% (dividend), 10% (interest), 20% (royalty)
Withholding tax
Yes
Exchange control

info
Basic taxes (briefly)

Personal tax
12%
Corporate tax (in detail)
Enterprises (legal entities) are normally subject to 15% corporate income tax
Capital gains tax. Details
Usual rate
VAT. Details
Standard rate applied in most cases is 12%
Other taxes
Excise tax; Water use tax; Property tax of legal entities; Property tax of individuals; Land tax of legal entities and individuals
Government fee
Yes
Stamp duty
Yes

Taxation of individuals

In Uzbekistan, personal income tax applies at the following rates:

Taxable income:

  • employment income, rental income, capital gains income, etc. – 12%;
  • dividends and interests for residents – 5%.

Corporate income tax

Resident corporations pay corporate income tax (CIT) on their income throughout the world.

Legal entities are normally subject to 15% corporate income tax.

The simplified tax regime is available to all legal entities with an annual turnover under UZS 1 billion and sole proprietorships with a turnover of UZS 100 million to UZS 1 billion. In this regime, turnover tax replaces CIT and VAT.

Value added tax

The standard value added tax (VAT) rate is 12%. This tax is imposed on the realization value of products, works and services. Export of goods is taxed at a 0% rate. There is a list of goods, works and services exempted from VAT (for example, certain educational, transportation, medical, financial, insurance services, import by individuals within limits).

VAT payers are all entities with a turnover exceeding UZS 1 billion as well as permanent establishments of foreign legal entities.

Withholding tax

Domestic rates of income tax are as follows:

  • dividends and interests for residents – 5%;
  • dividends and interests for non-residents – 10%;
  • insurance and reinsurance payouts – 10%;
  • royalties, services (including management and consulting services), rent, and other income – 20%.

Real estate tax

Real estate tax is imposed on property located in Uzbekistan and owned by Uzbek legal entities or non-resident individuals. The tax applies to buildings, unfinished constructions, railroads, main pipelines and residential real estate in Uzbekistan.

The property tax rate for legal entities is 1,5% (3% for overdue unfinished construction).

Individuals are subject to property tax imposed on residential and non-residential real estate, CIP, parking bays at rates of 0,34% to 1,5% of the cadastral value.

Social contributions

Employers must pay a social tax on the total payroll of the local and foreign personnel. This tax is charged by tax authorities. The rate is set at 12% for all kinds of entities, and it applies to certain new categories of taxpayers, including sole proprietorships and their employees, members of family businesses, farm enterprises, craftspeople, etc. State-funded organizations pay a 25% social tax.

Controlled foreign company rules

Controlled foreign company rules came into force on 1 January 2022.

Controlled foreign company rules are generally applicable to individuals and legal entities that are tax residents of Uzbekistan and own or control foreign legal entities and/or structures. The main goal of the controlled foreign company rules is taxation of undistributed profits of foreign companies and structures, such as trusts, funds, etc.

Transfer pricing

The tax code introduces detailed provisions on transfer pricing, including the definition of related parties, controlled transactions, pricing methods, document and reporting requirements, pricing agreements, etc.

There are five transfer pricing methods analogous to those used in international practice of transfer pricing (i.e. based on the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations) to analyze independent nature of controlled transactions.

International tax treaties

Uzbekistan has entered into 55 Double Tax Treaties (DTCs) with the following jurisdictions:

55 DTCs: Austria, Azerbaijan, Bahrain, Belarus, Belgium, Bulgaria, Great Britain, Hungary, Vietnam, Germany, Greece, Georgia, Egypt, Israel, India, Indonesia, Jordan, Iran, Ireland, Spain, Italy, Kazakhstan, Canada, Qatar, Kyrgyzstan, China, Kuwait, Latvia, Lithuania, Luxembourg, Malaysia, Moldova, the Netherlands, the UAE, Oman, Pakistan, Poland, Russia, Romania, Saudi Arabia, Singapore, Slovakia, Slovenia, Tajikistan, Thailand, Turkmenistan, Turkey, Ukraine, Finland, France, the Czech Republic, Switzerland, Estonia, South Korea, Japan.

Uzbekistan has not yet signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).

Foreign exchange controls

All payments in Uzbekistan must be made in sum (UZS).

Certain foreign exchange controls limitations apply to residents of Uzbekistan and foreign exchange transactions.

Individuals can bring cash into the country with no limitations. Individuals can also take cash out of the country without exceeding an equivalent of UZS 100 million without permission.

Legal entities, except for banks, are prohibited from bringing and withdrawing cash.

Resident individuals can open bank accounts in national and foreign currency with banks located in Uzbekistan and abroad.

Resident legal entities can open and use bank accounts outside Uzbekistan in accordance with resolution of the president or government and the international treaty that allows opening and use of accounts at foreign banks. Resident legal entities that have bank accounts outside Uzbekistan must inform tax authorities of opening, change or closure of an account at a foreign bank and must provide the Central Bank of Uzbekistan with quarterly reports on the flow of cash and other financial assets.

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