Uzbekistan
Corporate taxes and other direct taxes
In general, the concept is similar to the CIT approach used in developed countries worldwide. Taxable income is calculated as annual income minus expenses. It is only possible to deduct properly documented expenses provided that the expenses are connected with the taxable income. Dividends and capital gains are excluded from taxable income. The percentage of depreciation norms for fixed assets is set out in the Tax Code and is substantively similar to IFRS principles. Losses can be carried forward without limitation. The rules on the carrying forward of losses do not apply to losses generated during periods when a company has enjoyed tax benefits. There are thin capitalization rules. A CFC rule exists.
WHT applies to incomes paid to non-residents that are not registered for tax purposes in Uzbekistan. Taxable incomes are listed in the Tax Code. Uzbekistan has signed 54 treaties on avoidance of double taxation. Although the treaty rates prevail over the Tax Code, non-residents must have a duly issued tax residency certificate to be able to apply the treaty. The multilateral instrument (MLI) is not in force.
Small and medium businesses may enjoy a special tax regime according to which the Unified Tax on income is paid. This tax replaces CIT.
Level of attention paid by Tax Authority:
2023 is the first year TP reporting has to be submitted to the state authorities. The tax authorities may start audits on TP matters only after June 2023.
VAT and other indirect taxes
The VAT concept is quite similar to the concept applied in developed countries worldwide. The turnover subject to VAT is in general the total value of sales (Output VAT). The VAT paid to suppliers (input VAT) is deducted from Output VAT. Input VAT cannot be offset if the goods, works, or services purchased are not related to taxable turnover, the VAT-invoice is not issued by a supplier or issued with the violation of the legal requirements, the supplier is declared by a court to be inactive entity, etc. The VAT rate for the export of goods is 0% and there is a certain procedure for the refund of the related input VAT.
Excise Tax is paid by importers or sellers of:
1) Alcoholic products
2) Tobacco products
3) Oil & gas products
4) Motor vehicles.
Personal income tax / Social security system
Tax residents shall be recognized as an individual staying in the Republic of Uzbekistan if they do so for at least 183 calendar days in any consecutive 12-month period ending in the current tax period (calendar year). The concept is the same as worldwide.
The 12% Social Tax contains all types of contributions to the social system, including the pension scheme and access to the state medical system.
Wage related taxes in Uzbekistan |
Minimum wage |
Average wage in private sector |
Exchange rate UZS/EUR |
in EUR |
in UZS |
in EUR |
in UZS |
13536 |
78 |
1,050,000 |
400 |
5,414,400 |
Total wage cost |
87 |
112% |
448 |
112% |
Employer's social security and other contributions |
9 |
12% |
48 |
12% |
Gross salary |
78 |
100% |
400 |
100% |
Personal income tax |
9 |
12% |
48 |
12% |
Employees' contributions |
- |
0% |
- |
0% |
Net salary |
68 |
88% |
352 |
88% |