Uzbekistan Cross-Border Tax Guide 2026

Overview — Cross-Border Taxation in Uzbekistan

Uzbekistan's cross-border tax rules are governed by the Tax Code of Uzbekistan, transfer pricing regulations, and double tax treaties. The State Tax Committee has been strengthening its international tax capacity, including participation in the OECD's BEPS Inclusive Framework. Multinational enterprises operating in Uzbekistan must comply with transfer pricing documentation requirements, thin capitalisation rules, and withholding tax obligations. Non-residents earning Uzbekistan-source income are subject to withholding taxes at statutory rates, which may be reduced under applicable treaties. Uzbekistan has one of the largest DTT networks in Central Asia.

Transfer Pricing — OECD Guidelines

Uzbekistan's transfer pricing rules follow the OECD Transfer Pricing Guidelines. The regulations require that transactions between related parties be priced at arm's length. Related parties include companies under common control, parent-subsidiary relationships, and individuals with significant influence. Documentation requirements include a master file and local file for transactions exceeding prescribed thresholds (approximately UZS 5 billion). Country-by-country reporting applies for groups with consolidated revenue exceeding the equivalent of EUR 750 million. Acceptable transfer pricing methods include CUP, Cost Plus, Resale Price, TNMM, and Profit Split. Advance Pricing Agreements (APAs) are available. Penalties for non-compliance range from 20% to 50% of the tax adjustment plus interest.

Thin Capitalisation — 3:1 Debt-to-Equity

Uzbekistan's thin capitalisation rules limit interest deductions on related-party debt. The maximum allowable debt-to-equity ratio is 3:1 (debt exceeding equity by no more than 3 times). Interest on debt exceeding this ratio is disallowed as a deduction and may be recharacterised as a dividend for withholding tax purposes. The rules apply to all related-party debt, including loans from foreign parent companies, sister companies, and guaranteed third-party debt. Certain long-term financing from international financial institutions (EBRD, ADB, IFC) may be exempt. The Tax Committee may apply general anti-avoidance rules where debt arrangements lack commercial substance.

Withholding Taxes to Non-Residents

Payments to non-residents from Uzbekistan-source income are subject to withholding tax at standard rates (treaty rates may apply):

• Dividends — 10% (reduced to 5% under many DTTs)
• Interest — 10% (reduced to 5-10% under DTTs)
• Royalties — 20% (reduced to 10-15% under DTTs)
• Management & consulting fees — 20%
• Insurance premiums — 10%
• International transport — 6%

The payer must withhold the tax and remit it within 15 days of payment. Treaty relief requires the non-resident to provide a Certificate of Tax Residency and submit a treaty relief application.

Controlled Foreign Company (CFC) Rules

Uzbekistan's CFC rules attribute certain income of a foreign company to its Uzbek resident shareholders where the foreign company is controlled by Uzbek residents and is located in a low-tax jurisdiction. A foreign company is a CFC if Uzbek residents hold more than 50% of shares or voting rights. The attributed income includes dividends, interest, royalties, rent, and certain passive income. The CFC rules apply when the foreign company is subject to an effective tax rate of less than 60% of the Uzbek CIT rate (i.e., below 9%). The Uzbek shareholder reports their proportionate share of CFC passive income in their annual tax return. Active business income (manufacturing, trading) is not attributed.

Double Tax Treaties — Practical Application

Uzbekistan has over 60 double tax treaties. To claim treaty benefits, a non-resident must:

• Obtain a Certificate of Tax Residency from the home country tax authority
• Submit a treaty relief application (Form 1-TAT) to the State Tax Committee
• Provide the certificate and application to the Uzbek withholding agent
• Wait for Tax Committee approval (typically 10-15 business days)

Treaty benefits include reduced withholding tax rates and potential exemption from CGT on certain assets. Most treaties follow the OECD Model Convention. Limitation on Benefits (LOB) clauses in newer treaties restrict treaty access to genuine residents.

FAQs

Do I need to register for tax in Uzbekistan as a non-resident investor?

Non-residents earning Uzbekistan-source income subject to final withholding tax generally do not need to register. However, a non-resident with a permanent establishment must register and file CIT returns.

How do I claim a refund of excess WHT?

If WHT was deducted at the full statutory rate when a reduced treaty rate should have applied, a refund claim must be submitted to the State Tax Committee with a treaty relief application and Certificate of Residency.

Does Uzbekistan have a General Anti-Avoidance Rule (GAAR)?

Yes, the Tax Code includes a GAAR allowing the Tax Committee to recharacterise transactions entered into for tax avoidance. The GAAR applies to both domestic and cross-border arrangements.

Disclaimer

This guide provides general information about Uzbek cross-border taxation for the 2026 tax year. Tax laws and treaty provisions may change. Always consult with a qualified Uzbek international tax advisor or the State Tax Committee for advice specific to your situation. InvestmentKit does not provide tax advice.