United States-Uzbekistan Tax Treaty
Uzbekistan’s International Tax Compliance Rules
Quick Summary. Located in Central Asia, the Republic of Uzbekistan borders Kazakhstan, Kyrgyzstan, Tajikistan, Afghanistan and Turkmenistan. Uzbekistan is a presidential republic with the Oliy Majlis (a parliament) consisting of the Legislative Chamber (a lower chamber) and the Senate (an upper chamber), and is divided into 12 regions and the autonomous Republic of Karakalpakistan. Formerly a member of the U.S.S.R., Uzbekistan achieved independence in 1991.
The Uzbekistan legal system is a civil law system and incorporates the Constitution of the Republic of Uzbekistan, Laws of the Republic of Uzbekistan protecting private property and guaranteeing owner rights; the Civil Code of the Republic of Uzbekistan as well as other Codes regulating significant areas of business; Decrees of the President of the Republic of Uzbekistan; and Resolutions of the Cabinet of Ministers and other normative legal acts.
There are five prominent political parties in Uzbekistan: the Adolat Social Democratic Party, the National Democratic Party of Uzbekistan, the Democratic Party “Milliy Tiklanish”, the Liberal Democratic Party “Movement of Entrepreneurs and Businessmen” and the Ecologic Party of Uzbekistan.
On April 2019, adoption of the Presidential Decree NoПП-4300 initiated a large-scale privatization program.
In 2020, several notable tax were implemented to the Tax Code, including an increase in the general corporate income tax, a decrease to the value-added tax, and abolition of the excess profits tax. An e-services VAT was imposed on foreign entities. In addition, thin capitalization and beneficiary ownership rules became effective in 2020, and transfer-pricing rules, controlled foreign corporation (CFC) rules and group taxation rules were introduced, taking effect in subsequent years.
U.S.-Uzbekistan Tax Treaty
Currency. Uzbekistani Soum (UZS)
Common Legal Entities. Joint stock company, limited liability company, partnership, and branches.
Tax Treaties. Uzbekistan is party to more than 50 tax treaties.
Corporate Income Tax Rate. 12% generally.
Individual Tax Rate. 12%
Corporate Capital Gains Tax Rate. Based upon standard tax rates.
Individual Capital Gains Tax Rate. Ordinary tax rates.
Residence. Domicile in country on a permanent basis or present for 183 days.
Dividends.. 5% (residents) / 10% (nonresidents)
Interest. 5% (residents) / 10% (nonresidents)
Royalties. 20% (nonresidents)
Transfer Pricing. Based upon market rate. The law provides taxing authority with ability to adjust income from related party transactions.
CFC Rules. No.
Hybrid Treatment. N/a
Inheritance/estate tax. No.
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