Page 56 - CEE Tax Guide 2025
P. 56

Uzbekistan


                           Forvis Mazars LLC
                           8A Afrosiab street, office 501,
                           5  floor “Dmaar Plaza” Business
                            th
                           Center, Tashkent – Uzbekistan
                           Phone: +998 93 373 11 40
                           www.forvismazars.com/uz








           Corporate taxes and other direct taxes              assets is set out in the Tax Code and is substantively
                                                               similar to IFRS principles. Losses can be carried
           In general, the concept is similar to the CIT approach   forward without limitation. The rules on the carrying
           used in developed countries worldwide. Taxable      forward of losses do not apply to losses generated
            income is calculated as annual income minus        during periods when a company has enjoyed
           expenses. It is only possible to deduct properly    tax benefits. There are thin capitalization rules.
           documented expenses provided that the expenses      A CFC rule exists.
           are connected with the taxable income. Dividends
           and capital gains are excluded from taxable income.   WHT applies to incomes paid to non-residents that
           The percentage of depreciation norms for fixed      are not registered for tax purposes in Uzbekistan.
                                                               Taxable incomes are listed in the Tax Code.
            Transfer pricing in Uzbekistan                     Uzbekistan has signed 54 treaties on avoidance
                                                               of double taxation. Although the treaty rates prevail
            Arm’s length principle    Since 2020
                                                               over the Tax Code, non-residents must have a duly
            Documentation liability   Since 2022               issued tax residency certificate to be able to apply
                                                               the treaty. The multilateral instrument (MLI)
            APA                       Since 2022
                                                               is not in force.
            Country-by-Country   No   N/A
            liability                                          Small and medium businesses may enjoy a special
            Master file-local file   No  N/A                   tax regime according to which the Unified Tax
            (OECD BEPS                                         on income is paid. This tax replaces CIT.
            13) applicable
                                                               VAT and other indirect taxes
            Penalty
            lack of documentation  N/A  Less than 500 EUR.     The VAT concept is quite similar to the concept
                                                               applied in developed countries worldwide. The
            tax shortage        N/A   20% of tax shortage
                                                               turnover subject to VAT is in general the total value
            Related parties     N/A   Legal entities are       of sales (Output VAT). The VAT paid to suppliers
                                      considered to be related:
                                      –  legal entities are
                                        related if one legal
                                        entity holds a direct   VAT options in Uzbekistan  Applicable / limits
                                        or indirect participation
                                        in another legal        Distance selling     No
                                        entity and the share    Call-off stock       No
                                        of such participation
                                        in the charter          VAT group registration  No
                                        capital exceeds 20%
                                      –  an individual and      Cash accounting – yearly   No
                                        a legal entity are related   amount in EUR (approx.)
                                        if the individual holds
                                        a direct or indirect    Import VAT deferment  No
                                        participation in the legal
                                        entity and the share    Local reverse charge
                                        of such participation   Option for taxation
                                        in subscribed
                                        capital exceeds 20%.    letting of real estate  No

            Safe harbors        No    N/A                       supply of used real estate  No
            Level of attention paid   5/10                      VAT registration     1 bUZS (approx. EUR 77k)
            by Tax Authority                                    threshold

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