January 10, 2020

System of Taxes and Levies

 1.        Taxation System

1.1.       Legislation (laws and regulations – list)

1.2.       Authorized Bodies

1.3.       Types of taxes

1.4.       Approval Procedure

1.5.       Rate

1.6.       Taxes and levies

1.7.       Tax Base

1.8.       Payment Features

1.9.       Tax reporting

1.10.         Avoidance of double taxation (the country, particularities of regulation)

1.11.         Permanent establishment

1.12.         Constitution of PE

1.13.         Registration of PE with tax authorities

1.      Taxation System

First of all, It should be noted that the Tax Code of the Republic of Uzbekistan (hereinafter – Tax Code) was revised and adopted in new editions for several times. It has the editions as follows:

  • from January 1, 1998 to January 1, 2008 (was valid for ten years), the Tax Code of the Republic of Uzbekistan approved by the Law of the Republic of Uzbekistan dated April 24, 1997 No. 396-I;
  • from January 1, 2008 to January 1, 2020 (was valid for twelve years), the Tax Code of the Republic of Uzbekistan approved by the Law of the Republic of Uzbekistan dated December 25, 2007 No. ZRU-136;
  • from January 1, 2020, the Tax Code was enacted in the new edition by the Law of the Republic of Uzbekistan dated December 30, 2019 No. ZRU-599.

In accordance with Art.17 of the latest edition of Tax Code, the taxation system consists of taxes and levies. In this memorandum, we will analyze the essentials of taxation system and provided brief summary of the applicable taxes and levies.

1.1.      Laws and Regulations

The main legal and regulatory instruments in the field of taxation are as follow:

  • Constitution of the Republic of Uzbekistan;
  • Tax Code of the Republic of Uzbekistan of 30.12.2019;
  • Law on State Tax Service of 19.09.1997 No.193;
  • Resolution of the Legislative Chamber of Oliy Majlis of the Republic of Uzbekistan on the State Budget of the Republic of Uzbekistan, the Budgets of State Funds Earmarked for Special Purposes and the Main Directions of Tax and Budget Policy for 2019 of 17.11.2018 No.991-II;
  • Law on the State Budget Republic of Uzbekistan for 2020 of 09.12.2019 No.ZRU-589;
  • Regulation on the State Tax Committee of the Republic of Uzbekistan approved by Appendix No. 1 to the Resolution of the Cabinet of Ministers of 17.04.2019 No.320;
  • Decree of the President of the Republic of Uzbekistan on the Concept of Improving the Tax Policy of the Republic of Uzbekistan of 29.07.2018, No.UP-5468;
  • Regulation of the President of the Republic of Uzbekistan on the Forecast of the Main Macroeconomic Indicators and Parameters of the State Budget of Uzbekistan for 2019 and the Budgetary Targets in the Years 2020-2021 of 26.12.2018 No.PP-4086;
  • Decree of the President of the Republic of Uzbekistan on Measures to Further Improve the Tax Policy of the Republic of Uzbekistan of 26.09.2019, No.UP-5837;
  • Decree of the President of the Republic of Uzbekistan on Measures to Streamline the Provision of Tax and Customs Privileges of 27.07.2019 No.UP-5755.

1.2.      Authorized Bodies

In accordance with Art.25 of the Tax Code of the Republic of Uzbekistan authorized bodies are:

  • Tax Authorities – the State Tax Committee of the Republic of Uzbekistan, the Interregional State Tax Inspectorate for large taxpayers, the state tax departments of the Republic of Karakalpakstan, regions and the city of Tashkent, as well as state tax inspectorates of districts (cities);
  • Customs Authorities – the State Customs Committee of the Republic of Uzbekistan, the administration of the State Customs Committee of the Republic of Karakalpakstan, regions, the city of Tashkent, the specialized customs complex “Tashkent-AERO” and customs posts;
  • Government Agencies and Organizations that carry out collection functions.

1.3.      Types of Taxes

In accordance with Art.17 of the Tax Code  the following types of taxes are available:

  1. Value Added Tax;
  2. Excise Tax;
  3. Tax on Profit;
  4. Tax on Income of Physical Persons;
  5. Subsoil Use Tax;
  6. Tax for the Use of Water Resources;
  7. Property Tax;
  8. Land Tax;
  9. Social Tax.

1.4.      Approval Procedure

In accordance with Art. 78 of the Constitution, the establishment of taxes and other compulsory payments refers to the joint jurisdiction of the Legislative Chamber and the Senate of Oliy Majlis (Parliament). The concept of other compulsory payments is not used in the latest edition of the Code, instead, it uses the term of levies.

1.5.      Tax Rate

According to Art. 72 of the Tax Code, the tax rate is the amount of tax accruals per unit of measure of the tax base in percentage or absolute amount. As a general rule, all tax rates are established by this Code. However, the excise tax, land tax, tax on the use of water resources and tax on the extraction of individuals in a fixed amount are established by the Law on the State Budget of the Republic of Uzbekistan. Excise tax rates can be revised by decisions of the President of the Republic of Uzbekistan during the year, based on price dynamics and sales volume.

1.6.      Taxes and levies[1]

The system of taxes and levies also provides for a Simplified Tax System for calculating the Tax Base. The following table explains the general provisions of the taxes and levies in Uzbekistan.

Type of tax Payers Tax rate Due date
Tax on profit a) Taxpayers:

  • engaged in the production of cement (clinker);
  • engaged in the production of polyethylene granules;
  • the main activity of which is the provision of mobile services;
20% Tax is paid based on the results of the reporting (tax) period no later than the twentieth day of the month following the reporting period (Art. 340), the reporting period is the quarter (Art. 338).
b) Banks; 20%
c) Agricultural producers and fishery enterprises that meet the criteria provided for in Art. 57 of the Code, according to the profit received from the sale of their own agricultural products; 0%
d) Taxpayers engaged in social activities; 0%
e) Budget organizations receiving income from additional sources; 0%
f) Profit from the sale of goods (services) for export; 0%
g) Profit received from the provision of services by markets and shopping malls; 20%
g-1) Taxpayers included in the National Register of Electronic Commerce Entities engaged in Electronic Trade in Goods (services); 7.5%
h) Taxpayers, the sole participants (shareholdes) of which are public associations of persons with disabilities and in the total number of which persons with disabilities make up at least 50%, and the labour payment fund for persons with disabilities is at least 50% of the total labour payment fund; 0%
j) Income received by the People’s Bank of the Republic of Uzbekistan from the use of funds in individual accumulative pension accounts of citizens; 0%
k) Income in the form of dividends; 5% It is withheld by the tax agent[2] at the time of dividend payment and the tax amount is paid to the budget no later than the date of dividend payment (Art. 345(6)).
m) The remaining taxpayer except as specified in paragraphs “a)” – “k)”. 15% Tax is paid based on the results of the reporting (tax) period no later than the twentieth day of the month following the reporting period (Art. 340), the reporting period is the quarter (Art. 338).
Tax on income of physical persons Income of a resident of the Republic of Uzbekistan 12% Paid by a tax agent at the same time as income is paid to the taxpayer, but no later than the deadlines for submitting tax reports. (Art. 390(1)).
Resident income paid in the form of dividends and interest; 5%
Non-resident income paid in the form of dividends and interest; 10%
Non-resident income from the provision of transport services in international traffic; 6%
Non-resident income received under employment contracts (contracts) 20%
Non-resident income received under civil law contracts. 20%

Value Added Tax

  1. legal entities of the Republic of Uzbekistan;
  2. individual entrepreneurs whose income from the sale of goods (services) for the tax period exceeds one billion soums, or who transferred to the payment of Value Added Tax voluntarily;
  3. foreign legal entities selling goods (services) on the territory of the Republic of Uzbekistan, if the Republic of Uzbekistan is recognized as the place of sale of such goods (services);
  4. foreign legal entities operating in the Republic of Uzbekistan through Permanent Establishments;
  5. agent – a participant in an Ordinary Partnership Agreement, which is entrusted with the conduct of simple partnership affairs – for activities carried out within the framework of an Ordinary Partnership Agreement (joint activity agreement);
  6. persons transporting goods across the customs border of the Republic of Uzbekistan. These persons are recognized as taxpayers in accordance with customs legislation.

Unless otherwise provided in chapter 36 of the Code, the tax rate is set at 15%

The tax is paid at the end of each tax period no later than the deadline for submitting tax reports.

Tax reporting shall be submitted no later than the twentieth day of the month following the expired tax period (Art. 273).

Excise Tax
  1. producing goods subject to Excise Tax (excisable goods) on the territory of the Republic of Uzbekistan;
  2. selling natural gas to consumers;
  3. selling gas, diesel fuel to end consumers, including through gas stations, as well as gas through gas stations. For the purposes of applying this section, end consumers are legal entities and individuals who purchase gasoline, diesel fuel and gas for their own needs;
  4. agent – a participant in an Ordinary Partnership Agreement, which is entrusted with the conduct of simple partnership affairs – for activities carried out within the framework of an Ordinary Partnership Agreement;
  5. moving excisable goods across the customs border of the Republic of Uzbekistan. These persons are recognized as taxpayers in accordance with customs legislation.
  6. The following are also recognized as taxpayers:
  7. legal entities of the Republic of Uzbekistan providing telecommunication services of mobile communications (excisable services);
  8. foreign legal entities operating in the Republic of Uzbekistan through Permanent Establishments producing goods or importing goods subject to Excise Tax (Art. 283) .
Depends on the type of products and services Tax is paid no later than the deadline for submitting tax reports. Tax report is submitted to the tax authorities at the place of tax accounting monthly no later than the tenth day of the month following the tax period (Art. 292).
Subsoil Use Tax

Legal entities and individuals engaged in the search and exploration of deposits in the territory of the Republic of Uzbekistan, mining, extraction of useful components from mineral raw materials and (or) technogenic mineral formations (Art. 449).

 

Depends on the type of the extracted minerals

Tax payment is made by legal entities every month no later than the 20th day of the next month, and at the end of the year no later than the deadline for submission of Annual Financial Statements (Art. 454).

Water Use Tax
  • legal entities of the Republic of Uzbekistan;
  • legal entities – non-residents of the Republic of Uzbekistan, operating in the Republic of Uzbekistan through Permanent Establishments;
  • individual entrepreneurs using water for entrepreneurial activity;
  • Dekhkan farms (st.441 of the Tax Code).

The rate depends on the type of activity of the payer (Appendix No. 11 to the Law of the Republic of Uzbekistan dated December 9. 2019 N ZRU-589)

During the tax period, taxpayers, with the exception of:

  • agricultural enterprises,
  • legal entities – non-residents of the Republic of Uzbekistan, operating in the Republic of Uzbekistan through Permanent Establishments,
  • as well as Dekhkan Farms, pay advance tax payments.

To calculate the amount of advance payments, taxpayers until January 20 of the current tax period, and newly created no later than thirty days from the date of state registration, submit to the tax authorities at the place of water use or water consumption a certificate of the amount of tax for the current tax period.

Advance payments indicated in the certificate of the legal entity and submitted to the relevant tax authorities are paid:

by legal entities (with the exception of Turnover Tax payers) for which the amount of tax for the tax period is more than two hundred times of  the base calculated amount – no later than the 20th day of each month in the amount of one twelfth of the annual tax amount;

legal entities that are not payers of Turnover Tax, for which the amount of tax for the tax period is less than two hundred times the base calculated amount[3], as well as payers of Turnover Tax and private entrepreneurs – no later than the 20th day of the third month of each quarter in the amount of one fourth of the annual amount tax. (Art. 448).

Social tax
  • legal entities of the Republic of Uzbekistan;
  • legal entities – non-residents of the Republic of Uzbekistan;
  • certain categories of individuals.
a) Taxpayers, with the exception of those specified in clauses “b)”, “c)”, “d)” – 12%;

b) Budget organizations – 25%;

c) Association “SOS – Children’s Villages of Uzbekistan” – 7%;

d) Taxpayers using the labor of persons with disabilities working in specialized workshops, sections and enterprises – 4.7% (Art. 405).

Tax payment is made:

  • on a monthly basis no later than the 15th day of the month in which the business was carried out ;
  • members of Dekhkan Farms created with and without formation of a legal entity – until October 1 of the reporting year. In this case, the tax amount is calculated on the basis of the size of the base calculated amount established on the day of payment. (Art. 408).
Corporate property tax  

  1. legal entities of the Republic of Uzbekistan having property in the territory of the Republic of Uzbekistan that is an object of taxation in accordance with Art. 411;
  2. legal entities – non-residents of the Republic of Uzbekistan that own immovable property in the territory of the Republic of Uzbekistan.

The tax rate is set at a rate of 0.2 to 4% of the tax base, depending on the object (Art. 415).

The amount of tax payable for the tax period, taking into account advance payments, is paid to the budget no later than the deadline for submitting tax reports (Art. 417).

The tax is payable by non-residents of the Republic of Uzbekistan, not carrying out activities in the Republic of Uzbekistan through Permanent Establishments, once a year no later than February 15 of the year following the reporting tax period (Art. 417).

Land tax from legal entities Legal entities, including non-residents of the Republic of Uzbekistan, having land plots on the basis (title) of ownership, possession, use or lease (financial lease) (Article 425 of the Tax Code).

Rates are defined in the Law on the State Budget Republic of Uzbekistan for 2020, depending on the location of the legal entity.

Tax for non-agricultural land is paid:

Turnover Tax payers – by the 10th day of each first month of the quarter in the amount of one fourth of the annual tax amount;

taxpayers not related to payers of VAT – up to the 10th day of each month in the amount of one twelfth of the annual amount of tax. (Art. 432).

Tax for agricultural land is paid in the following order:

until September 1 of the reporting year – 30 percent of the annual tax amount;

until December 1 of the reporting year – the remaining tax amount.

Turnover Tax[4]
  1. legal entities of the Republic of Uzbekistan (hereinafter referred to as legal entities), whose total income for the tax period does not exceed one billion soums;
  2. private entrepreneurs whose income from the sale of goods (services) for the tax period exceeds one hundred million soums, but not more than one billion soums (Art. 461).

Turnover Tax does not apply to:

  1. legal entities and private entrepreneurs importing goods through the customs border of the Republic of Uzbekistan;
  2. legal entities producing excisable goods (services) and (or) persons engaged in mining operations;
  3. legal entities – agricultural producers if they have irrigated agricultural land with an area of fifty hectares or more;
  4. legal entities selling gasoline, diesel fuel and gas;
  5. legal entities engaged in the organization of a lottery;
  6. a proxy – a participant in General Partnership, which is entrusted with the conduct of business of a General Partnership – for activities carried out under the framework of a General Partnership;
  7. legal entities – owners of vacant buildings, non-residential buildings and construction in progress, as well as non-utilizing production facilities, for which a conclusion was made on their inefficient use, in the manner prescribed by law.
  8. legal entities involved in the construction of facilities (with the exception of maintenance and overhaul) at the expense of centralized sources of financing.
Rates are set in Art. 467 in the amount of to 25 % depending on the type of activity.

Tax is paid based on the results of the reporting (tax) period no later than the deadlines for submitting tax reports for the corresponding reporting (tax) period.

Tax reporting is submitted to the tax authority at the place of tax accounting, in the following periods:

  1. according to the results of the reporting period – not later than the fifteenth day of the month following the reporting period;
  2. based on the results of the tax period – not later than February 15 following the expired tax period (Art. 470).

The tax period is a calendar year. The reporting period is a quarter (Art. 469).

Levies

Payers

Tax rates

Payment period

Transport levies

Residents and non-residents of the Republic of Uzbekistan who purchase and (or) temporarily import vehicles into the Republic of Uzbekistan (Art. 456).
  1. levy for entry into the territory and transit through the territory of the Republic of Uzbekistan of motor vehicles from foreign countries, for the entry of one road carrier (with the exception of the entry into the territory and transit of freight vehicles of the Republic of Tajikistan, Kazakhstan and Turkmenistan)[1] 400 US dollars (Appendix No. 15 to the Law of the Republic of Uzbekistan dated December 12, 2019 №ZRU-589).
  2. The levy for the purchase and (or) temporary import of vehicles to the territory of the Republic of Uzbekistan paid by the owners (users) of vehicles when they are registered with the bodies of the Ministry of Internal Affairs of the Republic of Uzbekistan:
  • For new vehicles (not previously used), with the exception of domestic production – 3 percent of the acquisition price.
  • for vehicles in use:
  • as a percentage of the base calculated value for each horsepower, depending on the period of operation.
  1. A levy for entry into the territory and transit through the territory of the Republic of Uzbekistan of motor vehicles of foreign countries is levied upon entry into the territory of the Republic of Uzbekistan of a motor vehicle of a foreign state (Art. 460).
  2. The levy for the purchase and (or) temporary import of vehicles to the territory of the Republic of Uzbekistan is charged upon their state registration, re-registration with the bodies of the Ministry of Internal Affairs of the Republic of Uzbekistan (Art. 460 of the Tax Code).

1.7.      Tax Base

The tax base is one of the mandatory elements of taxation, which should be determined by law (Art. 69). In accordance with the Tax Code of the Republic of Uzbekistan, the tax base is a value, physical or other characteristic of the object of taxation (Art. 71).

The concepts of the object of taxation and the tax base are interconnected. The object of taxation is property, an action, the result of an action or other circumstance having a cost, quantitative or physical characteristic, with the presence of which tax legislation relates the occurrence of a tax obligation of a taxpayer (Art. 70).

It is not disputable, if the cost characteristics of the object are profit or the amount of income. However, what is the method of determination of the tax base, say, of land tax from legal entities? The tax legislation determines the object of taxation as land plots owned by legal entities on the basis of ownership, possession, use or leasehold (Art. 426). When determining the tax base for a land plot, the total land area is taken into account, minus the areas of land that are not taxable in accordance with art. 427(2) of the Tax Code. We can conclude that for each tax there is its own procedure for determining the tax base.

1.8.      Payment Features

Tax reporting is the taxpayer’s document that includes calculations and tax returns for each type of tax or income paid, as well as annexes to calculations and tax returns and which is compiled in the form approved by the State Tax Committee in consultation with the Ministry of Finance (Art. 81).

1.9.      Tax Reporting

Tax reporting is a document of the taxpayer, which includes in itself the calculations and tax declaration for each type of tax or on paid income and also the application to the calculation and tax declarations, drawn up on a form approved by the State Tax Committee of the Republic of Uzbekistan in coordination with the Ministry of Finance of the Republic of Uzbekistan (Article 81 of the Tax Code).

1.10.   Avoidance of Double Taxation

Double taxation is the simultaneous taxation in different countries the same tax revenue. Double taxation due to the fact that a tax non-resident (physical and legal person not residing permanently in the territory of the country, a citizen or subject of which it is) must pay taxes on worldwide income at the same time and at the place of their actual location and at the place of their citizenship. To avoid such conflicts, the country concluded an agreement on the avoidance of double taxation.

List of countries with which Uzbekistan has concluded are international e agreement s on avoidance of double taxation and prevention of evasion from payment of taxes:

Countries Date of signing Date of entry into force
1. Austria 14.06. 2000 1.08. 2001
2. Azerbaijan 27.05.1996 2.11.1996
3. Bahrain 5.06.2009 09.07.2009
4. Belarus 22.12.1994 11.01.1997
5. Belgium 14.11.1996 8.07.1999
6. Bulgaria 24.10.2003 21.10.2004
7. Hungary 17.04.2008 29.01.2009
8. Vietnam 28.03.1996 16.08.1996
9. Germany 7.09.1999 12.12.2001
10. Greece 1.04.1997 15.01.1999
11. Georgia 28.05.1996 20.10.1997
12. Egypt 21.09.1999
13. Israel 15.09.1998 09.03.1999
14. India 29.07.1993 25.01.1994
15. Indonesia 27.08.1996 11.11.1998
16. Iran 26.04.2002 18.01.2005
17. Italy 21.11.2000 26.05.2004
18. Kazakhstan 12.06.1996 21.04.1997
19. Canada 17.06.1999 14.09.2000
20. China 3.07.1996 3.07.1996
21. Korea 2.02.1998 25.12.1998
22. Kuwait 19.01.2004  –
23. Kyrgyzstan 24.12.1996 17.03.2000
24. Latvia 3.07.1998 23.10.1998
25. Lithuania 18.02.2002 11.11.2002
26. Luxembourg 02.07.1997 02.09.2000
27. Malaysia 06.10.1997 10.08.1999
28. Moldova 30.03.1995 28.11.1995
29. Netherlands 18.11.2001 27.05.2002
30. Oman 30.03.2009 20.06.2009
31. Pakistan 22.05.1995 12.09.1996
32. Poland 11.01.1995 29.04.1995
33. Portugal 11.09.2001 Not entered into force
34. Russian Federation 02.03.1994 27.07.1995
35. Romania 06.06.1996 17.10.1997
36. Saudi Arabia 18.11.2008 01.11.2010
37. Singapore 24.07.2008 28.11.2008
38. Slovakia 06.03.2003 20.10.2003
39. United Kingdom of Great Britain and Northern Ireland 15.10.1993 10.06.1995
40. Republic of Slovenia 11.02.2013 18.11.2013
4 1 . Thailand 23.04.1999 21.07.1999
4 2 . Turkmenistan 16.01.1996 27.11.1996
4 3 . Republic of Tajikistan 09.03.2018 06.06.2018
4 4 . Turkey 8.05.1996 30.09.1997
4 5 . Ukraine 10.11.1994 13.07.1995
4 6 . Finland 09.04.1998 07.02.1999
4 7 . France 22.04.1996 01.10.2003
4 8 . Czech 02.03.2000 15.01.2001
4 9 . Hashemite Kingdom of Jordan 22.11.2010 13.07.2011
50 . Switzerland 03.04. 2002 15.08.2003
51. United Arab Emirate 26.10.2007 25.02.2015
52 . Japan 18.01.1986 27.11.1986

Features of regulation. If the current agreement establishes rules that differ from those stipulated by the tax legislation of Uzbekistan, the rules of the agreement shall apply. However, you must remember that in Uzbekistan there is a mechanism for the application of the rules of the agreements, which is based on the premise of what that foreign legal person wishing to receive the benefit (in the part of the reduction rates of taxation down to zero), must prove that it has a permanent abode is in that country on an agreement with which it refers.

1.11.   Permanent Establishment

A Permanent Establishment of a Foreign Legal Entity in the Republic of Uzbekistan (hereinafter – PE) is a permanent place of business through which this foreign legal entity fully or partially carries out entrepreneurial activities in the Republic of Uzbekistan (Article 36(1) of the Tax Code).

.As PE is understood, in particular:

  1. any place of management, branch, department, bureau, office, office, cabinet, agency, factory, workshop, shopfloor, laboratory;
  2. the place of production, processing, assembly, packaging and packaging of goods;
  3. any place, including a warehouse used as a retail outlet;
  4. a mine (mine), an oil or gas well, quarry or any other place of extraction of natural resources;
  5. an installation or structure (including its installation) used for the study (exploration), development, extraction and (or) exploitation of natural resources, but only on condition that the installation or structure is used or ready for use for more than one hundred eighty-three days ;
  6. any place of carrying out activities (including control or observation) related to the pipeline, gas pipeline;
  7. any place where activities related to the installation, commissioning and operation of gaming machines (including consoles), computer networks and communication channels, attractions are carried out.

A PE is also recognized:

  1. as a construction site, construction, installation or assembly facility or related supervisory (control) activity, provided that such a site, facility or activity exists or continues for more than one hundred eighty-three days during any consecutive twelve-month period;
  2. during the provision of services, including consulting services, performed by this foreign legal entity through its employees or other personnel hired by it for these purposes at least one hundred eighty-three days during any consecutive twelve-month period.

1.12.   Constitution of PE

The activity of a foreign legal entity constitutes a PE in accordance with the provisions of Article 36 of the Tax Code from the date of commencement of such activities in the Republic of Uzbekistan.

The date of commencement of activities by a foreign legal entity in the Republic of Uzbekistan for the application of this Code shall be the date

  1. the conclusion of any next contract (agreement, agreement) for:
    1. the provision of services in the Republic of Uzbekistan, including under the agreement on joint activities;
    2. the granting of authority to commit acts on his behalf in the Republic of Uzbekistan;
    3. the acquisition of goods in the Republic of Uzbekistan for use or sale on the territory of the Republic of Uzbekistan;
    4. the acquisition of services for the provision of services in the Republic of Uzbekistan;
  2. conclusion of the first labor contract (agreement, contract) in order to carry out activities in the Republic of Uzbekistan;
  3. the arrival in the Republic of Uzbekistan of a non-resident individual, the hiring of an employee or other personnel by a foreign legal entity to fulfill the terms of the contract.

1.13.   Registration of PE with Tax Authorities

PE is obliged not later than one hundred eighty three calendar days from the date of the start of this activity to submit to the tax authority an application for registration as a taxpayer. The following original or translated notarized copies in Uzbek are attached to this statement:

  1. a document confirming state registration in the country in which this legal entity – non-resident is established;
  2. special permits or licenses (if any);
  3. a power of attorney or other document (if any) certifying the right to act on behalf of a legal entity – non-resident;
  4. an agreement (if any), the execution of which leads to the formation of a permanent establishment.

However, the fact of registration with the state tax service of the PE does not mean the moment of formation of this PE. It should be noted, that the PE is deemed established regardless of the will of the legal entity – non-resident.


[1] Notes for the levies:

  1. For the passage of heavy and bulky vehicles of foreign states through the territory of the Republic of Uzbekistan, along with the payment of the levy at the rates provided for by this appendix, an additional levy is charged in the amounts established by the Cabinet of Ministers of the Republic of Uzbekistan dated January 11, 1995 No. 11.
  2. When transporting goods from third countries to the Republic of Uzbekistan and exporting goods from the territory of the Republic of Uzbekistan from trucks of Turkmenistan, an additional levy of $ 175 is charged.
  3. When transporting humanitarian goods, a reduction factor of 0.5 is applied to the rate of levy levied on the entry and transit of vehicles.
  4. If other rules are established by an international treaty of the Republic of Uzbekistan, the rules of the international treaty shall apply.

[1] Provided information is not exhaustive.

[2] Tax agents are persons who are charged with calculating, withholding from the taxpayer and transferring taxes to the budget system in accordance with this Code (Article 23 of the Tax Code).

[3] In the Republic of Uzbekistan the base calculated amount is 223,000 soums, which is equivalent to 24 US dollars.

[4] Turnover Tax introduced instead of Unified tax payment (UTP)

[5] Notes:

  1. For the passage of heavy and bulky vehicles of foreign states through the territory of the Republic of Uzbekistan, along with the payment of the levy at the rates provided for by this appendix, an additional levy is charged in the amounts established by the Cabinet of Ministers of the Republic of Uzbekistan dated January 11, 1995 No. 11.
  2. When transporting goods from third countries to the Republic of Uzbekistan and exporting goods from the territory of the Republic of Uzbekistan from trucks of Turkmenistan, an additional levy of $ 175 is charged.
  3. When transporting humanitarian goods, a reduction factor of 0.5 is applied to the rate of levy levied on the entry and transit of vehicles.
  4. If other rules are established by an international treaty of the Republic of Uzbekistan, the rules of the international treaty shall apply.