Uzbekistan Tax Residency Guide 2026
Tax residency in Uzbekistan determines whether a person or company is taxed on worldwide income or only on Uzbekistan-source income. The 183-day rule applies to individuals, while companies are resident if incorporated in Uzbekistan or have their place of effective management in Uzbekistan. Uzbekistan has one of the largest double tax treaty networks in Central Asia with 60+ countries, which can prevent double taxation and reduce withholding tax rates.
Overview — Tax Residency in Uzbekistan
Tax residency is the foundational concept determining the scope of taxation in Uzbekistan. Resident individuals are taxed on their worldwide income; non-residents are taxed only on Uzbekistan-source income. Residency is defined under the Tax Code of Uzbekistan. For individuals, the test is primarily based on physical presence (183 days) or having a permanent home in Uzbekistan. For companies, residency follows incorporation or place of effective management. The State Tax Committee applies these rules and may challenge arrangements designed to artificially avoid residency status. Uzbekistan's extensive DTT network helps resolve dual residency issues.
Individual Residency — 183-Day Rule
An individual is considered a tax resident of Uzbekistan if they meet any of the following conditions:
- Physical presence — present in Uzbekistan for 183 days or more in any consecutive 12-month period
- Permanent home — has a permanent home available in Uzbekistan (whether owned or rented)
- Centre of vital interests — personal and economic interests are centred in Uzbekistan
- Habitual abode — customarily resides in Uzbekistan
Day counting includes both partial days and full days. The 183-day test applies to any consecutive 12-month period, not just the calendar year. Diplomatic personnel and certain government officials may be treated as residents regardless of physical presence. Expatriates working in Uzbekistan should track their presence carefully.
Corporate Residency
A company is tax resident in Uzbekistan if either of the following conditions is met:
- Incorporation — the company is incorporated or registered under Uzbek law
- Place of effective management (POEM) — the place where key management and commercial decisions are made is in Uzbekistan
Foreign companies that have their central management and control exercised in Uzbekistan may be deemed resident regardless of where they are incorporated. The POEM test follows OECD guidance, considering factors such as board meeting locations, where senior executives operate, and where strategic decisions are made. A foreign-incorporated company that manages its affairs from Uzbekistan is at risk of being treated as resident.
Source Rules — Uzbekistan-Source Income
Non-residents are taxed only on income derived from sources in Uzbekistan. The Tax Code defines specific source rules:
- Employment income — sourced where duties are performed
- Business income — sourced through a permanent establishment in Uzbekistan
- Property income — sourced where the property is located
- Dividends — sourced where the paying company is resident
- Interest — sourced where the payer is resident
- Royalties — sourced where the intellectual property is used
Income sourced in Uzbekistan by a non-resident is subject to withholding tax at applicable rates, which may be reduced under a DTT.
Double Tax Treaties — 60+ Countries
Uzbekistan has one of the most extensive DTT networks in Central Asia, with over 60 comprehensive double tax treaties. Key treaties include:
- China — 5% dividend (≥10%), 10% interest
- Germany — 5% dividend (≥10%), 10% interest
- South Korea — 5% dividend (≥10%), 10% interest
- Russia — 10% dividend, 10% interest
- United Kingdom — 5% dividend (≥10%), 10% interest
- Singapore — 5% dividend (≥10%), 10% interest
- UAE — 5% dividend, 10% interest
- Other CIS countries — Kazakhstan, Azerbaijan, Belarus, Kyrgyzstan, Tajikistan, Turkmenistan
Treaties generally reduce WHT rates on dividends, interest, and royalties. To claim treaty benefits, the recipient must provide a Certificate of Tax Residency and submit a treaty relief application to the State Tax Committee.
FAQs
If I work remotely for a foreign company while in Uzbekistan, am I taxable?
If you are physically present for 183+ days, you are a tax resident and must declare worldwide income including foreign salary. If present for fewer than 183 days, only Uzbekistan-source income is taxable.
How do I prove I am not a resident for tax purposes?
Maintain records of travel dates, visa stamps, employment contracts, rental agreements abroad, and tax returns from your home country. A Certificate of Tax Residency from your home country is strong evidence.
Can I be resident in two countries at once?
Yes, dual residency is possible. The applicable DTT will contain tie-breaker clauses (permanent home, centre of vital interests, habitual abode, nationality) to determine primary taxing rights.
Disclaimer
This guide provides general information about Uzbek tax residency for the 2026 tax year. Tax laws and treaty provisions may change. Always consult with a qualified Uzbek tax advisor or the State Tax Committee for advice specific to your situation. InvestmentKit does not provide tax advice.