Page 54 - CEE Tax Guide 2024

Uzbekistan Excise Tax is paid by importers or sellers of:
1) Alcoholic products
2) Tobacco products
3) Oil & gas products
4) Motor vehicles.

Mazars Personal income tax / Social security system
8A Afrosiab street, office 501, 5th
floor “Dmaar Plaza” Business Center, Tax residents shall be recognized as an individual staying
Tashkent – Uzbekistan in the Republic of Uzbekistan if they do so for at least 183
Phone: +998 93 373 11 40 calendar days in any consecutive 12-month period ending
E-mail: infoca@mazars.kz 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.
Corporate taxes and other direct taxes when a company has enjoyed tax benefits. There are thin
capitalization rules. A CFC rule exists.
In general, the concept is similar to the CIT approach Wage related taxes in Uzbekistan Minimum wage Average wage
used in developed countries worldwide. Taxable income WHT applies to incomes paid to non-residents that are not in private sector
is calculated as annual income minus expenses. It is only registered for tax purposes in Uzbekistan. Taxable incomes in EUR in UZS in EUR in UZS
possible to deduct properly documented expenses are listed in the Tax Code. Uzbekistan has signed 54 treaties Exchange rate UZS/EUR 13.53
provided that the expenses are connected with the taxable on avoidance of double taxation. Although the treaty rates 78 1,050,000 400 5,414,400
income. Dividends and capital gains are excluded from prevail over the Tax Code, non-residents must have a duly Total wage cost 87 112.00% 448 112.00%
taxable income. The percentage of depreciation norms for issued tax residency certificate to be able to apply the treaty.
fixed assets is set out in the Tax Code and is substantively The multilateral instrument (MLI) is not in force. Employer's social security and other contributions 9 12.00% 48 12.00%
similar to IFRS principles. Losses can be carried forward Small and medium businesses may enjoy a special tax Gross salary 78 100.00% 400 100.00%
without limitation. The rules on the carrying forward regime according to which the Unified Tax on income Personal income tax 9 12.00% 48 12.00%
of losses do not apply to losses generated during periods
is paid. This tax replaces CIT. Employees' contributions – 0.00% – 0.00%
VAT and other indirect taxes Net salary 68 88.00% 352 88.00%
Transfer pricing in Uzbekistan
The VAT concept is quite similar to the concept applied
Arm’s length principle ü Since 2020 in developed countries worldwide. The turnover subject
Documentation liability ü Since 2022 to VAT is in general the total value of sales (Output VAT).
APA ü Since 2022 The VAT paid to suppliers (input VAT) is deducted from
Output VAT. Input VAT cannot be offset if the goods, works,
Country-by-Country – or services purchased are not related to taxable turnover,
liability No the VAT-invoice is not issued by a supplier or issued with
Master file-local file the violation of the legal requirements, the supplier
(OECD BEPS 13) No –
applicable is declared by a court to be inactive entity, etc. The VAT
Penalty rate for the export of goods is 0% and there is a certain
procedure for the refund of the related input VAT.
lack of documentation ü Less than 500 EUR.
tax shortage ü 40% of tax shortage.
Legal entities are considered VAT options in Applicable / limits
to be related: Uzbekistan
- legal entities are related
if one legal entity holds a direct Distance selling No
or indirect participation
in another legal entity and the Call-off stock No
share of such participation in the
Related parties charter capital exceeds 20% VAT group registration No
- an individual and a legal entity
are related if the individual holds Cash accounting – yearly
a direct or indirect participation amount in EUR (approx.) No
in the legal entity and the
share of such participation Import VAT deferment No
in subscribed capital
exceeds 20%. Local reverse charge ü
Safe harbors No – Option for taxation
2023 is the first year TP letting of real estate No Ludmila Dyakonova
reporting has to be submitted
Level of attention paid by Tax to the state authorities. supply of used real estate No Partner
Authority The tax authorities may start Phone: +7 727 355 40 00
audits on TP matters only after VAT registration 1 bUZS (approx. EUR 77k) E-mail: ludmila.dyakonova@mazars.kz
June 2023. threshold

54 Mazars Central and Eastern European tax guide 2024 Central and Eastern European tax guide 2024 Mazars 55