Tax Compliance in Uzbekistan for Foreign Companies 2026: Permanent Establishment, VAT and Withholding Tax

As of October 2026, a foreign company pays tax in Uzbekistan in one of three ways: through a permanent establishment (PE) that it must register with the tax authority, through withholding tax and VAT deducted by its Uzbek customers, or through its own VAT registration if it sells electronic services to individuals. A PE arises from a fixed place of business, a dependent agent, a construction site lasting more than 183 days or services lasting 183 days or more in any 12 months (Art. 36 of the Tax Code), and it pays 15% profit tax plus a further 10% on its net profit. Without a PE, the Uzbek payer withholds 10% from dividends and interest and 20% from royalties and management, technical and consulting fees, and the payer applies a lower treaty rate at payment only if the residence certificate reaches it no later than the payment date (Art. 357).

In short

• PE thresholds. A construction site after more than 183 days, services through staff after 183 days in any 12 months (Art. 36 of the Tax Code); treaties set their own periods, most often 12 months for a site.
• PE registration. Within 30 calendar days if the contract runs longer than 183 days, otherwise no later than 183 days; operating unregistered costs 10% of income, at least UZS 10 million (Arts. 130 and 219).
• Withholding tax. 10% on dividends and interest, 6% on international freight and telecoms, 20% on royalties, services and other income, paid no later than the next day (Arts. 353 and 355).
• Digital services. A provider selling electronic services to individuals registers within 30 days and pays 12% VAT quarterly; in B2B sales the buyer withholds it (Arts. 278–282).
• Reverse charge. An Uzbek buyer of a non-resident's services withholds 12% VAT even if it pays turnover tax itself (Arts. 255 and 462).
• Local subsidiary. 15% profit tax and 12% VAT, or turnover tax (base rate 4%) on income up to 12,000 BRV, which is UZS 5.28 billion (Decree UP-100, item 2; Art. 461 of the Code still says UZS 1 billion).

When a foreign company has a permanent establishment

Under Article 36 of the Tax Code, a PE is a permanent place of business through which a foreign company carries on business in Uzbekistan in whole or in part. It arises in three ways.

• A place: a place of management, branch, office, workshop, a place where goods are produced or packed, a warehouse used as a sales point, a mine or a well.
• Time: a construction, installation or assembly site, or supervision of it, lasting more than 183 days in any 12-month period; services, including consulting, provided through employees or hired personnel for at least 183 days in any 12 months on the same or connected projects. Periods worked on one site by related companies are added together.
• A person: someone who habitually concludes contracts on the company's behalf or plays the principal role in concluding them. A commission agent with no authority to sign does not create a PE unless it works mainly for related foreign companies.

Storing and displaying the company's own goods, purchasing and collecting information do not create a PE unless they complement other activities of the company and its related parties in Uzbekistan (parts 5–7). Seconding staff to an Uzbek company does not create a PE if three conditions are met together: the staff act on behalf and in the interests of the recipient, the sending company is not responsible for their results, and its income is no more than 10% of its costs. Activity starts on the date of a services contract, the first employment contract or the arrival of staff (part 14).

A double tax treaty takes precedence (Art. 2 of the Tax Code): under the UK–Uzbekistan convention, for example, a building site is a PE only if it lasts more than 12 months (Art. 5). A representative office accredited by the Ministry of Investment, Industry and Trade (state fee via the Single Portal 43.2 BRV, or UZS 19,008,000; 5 working days) is not a PE while it performs auxiliary functions. It may not carry on commercial activity, and for a breach the ministry may terminate it (items 7 and 40 of the Regulation approved by CM Resolution No. 76, Uzbek text), so selling through it risks both PE status and the loss of accreditation (branches and representative offices).

Registering a PE and how it is taxed

• Deadline. The application is filed within 30 calendar days of the start of activity if the contract, or several contracts together, run longer than 183 days; otherwise no later than 183 calendar days (Art. 130). The Tax Committee's non-resident portal tax.uz has an online application.
• Documents: originals or notarised copies translated into the state language, namely proof of registration in the home country, licences and a power of attorney if any, and the contract that creates the PE. There is no state fee (Art. 126).
• Customers. Until registration they withhold tax at source, and the tax is credited afterwards (Art. 350); they stop withholding once they hold a tax authority certificate confirming that the PE is registered (Art. 354).
• Closing. Deregistration within 15 calendar days of ending the activity (Art. 129); the final return and activity report within one month (Art. 349).

A PE calculates profit tax itself, at 15% for most taxpayers (Arts. 337 and 347). Royalties, service fees and interest paid to the head office are not deductible, and head-office overheads only where the treaty allows it (Art. 348). Net profit after tax is treated as a dividend and taxed at 10% or at the lowest treaty rate for dividends (Art. 347); without a treaty the total is 23.5% (15% plus 10% of the remaining 85%). A PE pays VAT (Art. 237), and turnover tax is open only to Uzbek legal entities (Art. 461).

Withholding tax on payments to non-residents

The tax agent is the Uzbek payer, whether a company, a sole proprietor, a PE or a representative office: it withholds tax from every payment of Uzbek-source income to a non-resident without a PE (Arts. 351–352).

Management, technical and consulting fees are taxed even when the work is done abroad, while most other services performed outside Uzbekistan are not (Art. 351). The tax is paid no later than the day after the payment and the return is filed by the 20th of the following month (Art. 355); if the tax was not withheld, the agent pays it from its own funds together with late-payment interest (Art. 354). For dividends, including the 5% rate on JSC shares, see our article on dividend withholding tax.

Treaty relief: the certificate comes first

The agent applies a treaty exemption or reduced rate itself if the tax residence certificate is received no later than the payment date and, for dividends, interest and royalties, the recipient is the beneficial owner (Art. 357). An original with an apostille or legalisation, a notarised copy or a printout from the competent authority's website will do; a certificate that names no period is valid for its calendar year of issue (Art. 358). A refund of tax withheld in excess can be claimed within three years of payment (Arts. 104 and 357).

A treaty can exempt service fees entirely if the provider has no PE: under Art. 7 of the UK convention (as amended by the 2018 Protocol), for example, such profits are taxed only in the UK; check any other treaty against its own text. The agent must first check whether services on connected projects have created a PE, and if they have, the exemption does not apply (Art. 357).

Source: the Tax Committee's table of treaty provisions (updated 6 March 2026). 0% applies to interest owned or guaranteed by the government. Where the table gives a single figure, it does not separate sites from services, so check the treaty text; for the UK, 12 months is the building-site period (Art. 5 of the convention).

VAT on electronic services: the "Google tax"

Since 1 January 2020, when the new edition of the Tax Code took effect (Law ZRU-599, Art. 6), foreign companies that sell electronic services to individuals in Uzbekistan have had to register with the tax authority and pay VAT themselves (Chapter 39 of the Tax Code).

• What is covered: the 14 examples in Art. 282, including software and games, streaming, online advertising, marketplaces, hosting and cloud services. Not covered: goods delivered in the ordinary way, software on physical media, consulting by email and internet access.
• The buyer is in Uzbekistan if any one indicator points there: place of residence, an Uzbek bank or payment operator, IP address, or phone country code (Art. 241).
• Registration no later than 30 calendar days after sales start (Art. 279), online at the Tax Committee's VAT office. According to the portal, it takes an extract from the foreign register and a copy of the passport of the director or authorised person, and the personal cabinet is opened within 15 working days. This is tax registration, not registration of a company.
• Calculation: 12% (Art. 258) is included in the price, so a UZS 112,000 subscription contains UZS 12,000 of VAT; the period is a quarter, currency is converted at the Central Bank rate on the last day of the month of payment (Art. 280), and the return and payment are due by the 20th of the month after the quarter (Art. 281).
• B2B: if the buyer is an Uzbek company or a PE, the buyer is the tax agent (Art. 278), and the provider does not need to register for those sales.

A foreign intermediary that collects payment from individuals under an agency agreement is the tax agent in place of the provider. From 12 December 2026 the regime also covers goods: see VAT for foreign sellers on marketplaces.

Reverse-charge VAT on services bought from non-residents

Most services are supplied where the buyer operates (Art. 241), so services an Uzbek company buys from abroad usually carry Uzbek VAT. The buyer, whether a company, a sole proprietor or a PE, is the tax agent: it calculates, withholds and pays 12% even if it is not a VAT payer (Art. 255) or pays turnover tax (Art. 462).

• Contract silent on VAT: the tax is inside the price, so of USD 11,200, USD 1,200 is VAT and the provider receives USD 10,000 (Art. 255, part 1).
• Price stated without Uzbek VAT: the buyer pays 12% on top from its own funds, USD 1,344 on USD 11,200 (part 7).
• Credit only after the VAT has been paid to the budget (Art. 266); an agent that is not a VAT payer files a return by the 20th of the month following the period of payment (Art. 273).
• Exempt services (Arts. 243–245) carry no reverse charge.

The same consulting fee may also bear 20% withholding tax unless a treaty removes it.

Is there a fiscal representative in Uzbekistan?

The Tax Code has no status of a representative who would account for VAT in place of a non-resident. Those functions are split as follows:

• The tax agent (Art. 23): the Uzbek counterparty calculates, withholds and pays the tax.
• An authorised representative (Art. 24): a tax consultancy or another person acting under a contract or a power of attorney; officials of tax, finance, customs and other state bodies cannot act as representatives.
• Self-registration: an e-service provider registers through tax.uz and a PE registers itself, and the non-resident's taxpayer duties can be placed on the PE (Art. 347).

The representative must read the personal cabinet: a document counts as received once read, and no later than three days after it is sent (Art. 19).

Local subsidiary: turnover tax or the general regime

A subsidiary LLC is an Uzbek legal entity (registration is covered in our guide to an LLC with a foreign founder).

As of October 2026, Arts. 461–462 of the Tax Code still name a UZS 1 billion threshold and exclude importers. Decree UP-100 changed the rules directly, without amending the Code: the 12,000 BRV threshold applies from 1 June 2026 (item 2), mandatory VAT status for importers is abolished (item 9(b)), and amendments to the legislation were only ordered to be drafted (item 14). In its press release of 27 May 2026 the Tax Committee confirmed that importers with income up to 12,000 BRV may use turnover tax. Until the Code is amended, keep the decree and the press release in the file that supports your choice of regime. Excisable production, mining, audit firms and tax consultancies cannot use turnover tax (Art. 461), and a new LLC chooses it at registration (Art. 462).

Transfer pricing

Companies are related if, among other things, one holds more than 20% of the other directly or indirectly (Art. 37).

• Control: transactions with a related non-resident, with no amount threshold; between two Uzbek residents only above UZS 5 billion a year, or above UZS 500 million where one party is exempt from profit tax or enjoys a tax benefit, uses a special regime or operates in a special economic zone (Art. 180). Foreign trade in exchange-traded commodities and deals with offshore counterparties are controlled even without a relationship (Art. 181).
• Notification by the deadline for the annual financial statements (Art. 182); documentation only on request, not earlier than 1 June of the following year, within 30 calendar days (Arts. 193 and 195).
• Penalty: 40% of the underpaid tax (Art. 226); after year-end the base can be adjusted voluntarily (Art. 177).

Key filing and payment deadlines

Typical mistakes

• Counting 183 days contract by contract, although connected projects and related companies are added together (Arts. 36 and 130).
• A local manager or a representative office signing contracts: that is a dependent agent or a PE.
• A residence certificate that arrives after the payment: the full rate is withheld.
• A turnover-tax subsidiary forgetting that it is a tax agent on payments to its parent.

How Pactum helps

• We review contracts, secondments and the role of local staff for PE risk before day 183.
• We handle PE and e-services VAT registration and act as your authorised representative under a power of attorney.
• We assemble the treaty file (certificate, beneficial ownership, timing) and support refunds of tax withheld in excess.
• We draft the tax terms of your contracts: contract review from UZS 2,000,000, foreign trade contracts from UZS 4,000,000.
• We choose the regime for a subsidiary and register it: tax optimisation from UZS 5,000,000, company registration from UZS 1,500,000.

We handle the legal side together with your accountant, not instead of them; court disputes are handled by a partner bureau's advocate under a separate agreement. Start with a lawyer consultation: 60 minutes, UZS 300,000, credited toward the service. Phone +998 99 050 50 70, Telegram, info@pactum.uz; office at 21 Afrosiyob Street, Tashkent. More on the tax compliance in Uzbekistan page.

FAQ

What does tax compliance in Uzbekistan involve for a foreign company?

First establish whether you have a PE. If you do, it means registration, profit tax, VAT and an activity report; if you do not, your Uzbek customers withhold the taxes, and what they need from you is a residence certificate and prices that account for Uzbek VAT.

Is fiscal representation required in Uzbekistan?

No, Uzbek law has no such status. A non-resident either registers itself (as a PE or through tax.uz) or pays through its Uzbek tax agent, and it may act through an authorised representative under a power of attorney (Art. 24 of the Tax Code).

What is the withholding tax rate in Uzbekistan?

10% on dividends, interest and insurance premiums, 6% on international freight and telecoms, and 20% on royalties, services and other income (Art. 353 of the Tax Code). A treaty lowers the rate, often to between 0% and 10%: at payment if the certificate is provided no later than the payment date (Art. 357), otherwise through a refund claimed within three years (Art. 104).

When does a foreign company have a permanent establishment in Uzbekistan?

When it has a fixed place of business or a dependent agent, or when a construction site lasts more than 183 days, or services 183 days or more, in any 12 months (Art. 36 of the Tax Code). Treaties set their own periods, most often 12 months for a site.

Do foreign digital service providers need to register for VAT in Uzbekistan?

Yes, if they sell electronic services to individuals and collect payment themselves: within 30 calendar days, through tax.uz, paying 12% VAT quarterly (Arts. 278–281 of the Tax Code). For sales to Uzbek companies, the buyer withholds the VAT.

Can a tax firm represent a foreign company before the Uzbek tax authority?

Yes, under a contract or a power of attorney (Art. 24 of the Tax Code). When choosing tax advisory services, ask for written positions that cite the Code and the treaty, and check that the adviser knows both the 12,000 BRV threshold under UP-100 and the fact that Art. 461 of the Code still says UZS 1 billion.

Sources

• Tax Code of the Republic of Uzbekistan, Arts. 2, 19, 23–24, 36–37, 104, 126, 129–130, 177–195, 219, 226, 237–282, 337–358, 461–470 (Russian text)
• Presidential Decree No. UP-100 of 26 May 2026 (Russian text)
• Decree No. UP-115 of 23 June 2026: BRV of UZS 440,000 from 1 September 2026 (Russian text)
• Tax Committee: provisions of international treaties (in Russian)
• Tax Committee: press release of 27 May 2026 on UP-100 (in Russian)
• NAPP and the Tax Committee: notice of 6 March 2026 on electronic service providers
• my.gov.uz: accreditation of representative offices (in Russian)
• Cabinet of Ministers Resolution No. 76 of 7 February 2024: Regulation on accreditation of representative offices (Uzbek text)
• UK–Uzbekistan Double Taxation Convention and 2018 Protocol (gov.uk)
• Law No. ZRU-599 of 30 December 2019: new edition of the Tax Code, in force from 1 January 2020, Art. 6 (Russian text)