VAT for Foreign Sellers on Uzbekistan Marketplaces from 12 December 2026: Who Pays

From 12 December 2026, foreign companies that sell goods to individuals in Uzbekistan through electronic trading platforms must account for 12% VAT. This is the effect of Law No. ZRU-1173 of 10 September 2026, which extends to goods the regime that previously applied only to electronic services, so Uzbekistan now taxes non-resident e-commerce sellers on the same footing as foreign digital service providers. A seller that collects payment itself must register with the tax authority no later than 30 calendar days after sales begin; if the money passes through an Uzbek platform or an intermediary under an agency agreement, that tax agent will, as a rule, withhold the tax. As of the publication date, October 2026, the implementing regulations have not yet been adopted.

Key points

• What changes. From 12 December 2026, Chapter 39 of the Tax Code covers not only non-residents' electronic services but also the sale of goods to individuals through electronic platforms.
• When a sale is taxable. When the buyer's place of residence and the place of delivery are both in Uzbekistan.
• Who pays. The payer is the foreign seller. The tax agent is an intermediary that settles with individuals under a mandate, commission, agency or similar agreement with the seller (Art. 278(3)–(4)), or an Uzbek platform that processes payments in favor of the seller (Art. 278(5)).
• Registration. Required for a seller that collects payment itself and for a foreign intermediary acting as an agent. This is tax registration, not the registration of a company.
• Calculation. The rate is 12%, tax is included in the price, the tax period is a quarter, and the return and payment are due by the 20th of the month after the quarter.
• For platforms. Subsidiary liability for sellers, license checks, algorithm transparency and separate bank accounts; notification under Order No. 24 of the National Agency for Prospective Projects (NAPP) has applied since 24 September 2026.

What takes effect on 12 December 2026

ZRU-1173 was signed on 10 September and published on 11 September 2026. Under its Art. 5 it enters into force three months after publication, that is, on 12 December 2026.

In the Tax Code, Chapter 39 is now titled "Specifics of Taxation of Foreign Legal Entities Providing Services in Electronic Form or Selling Goods Through Electronic Trading Platforms". Arts. 278 and 279 are restated, Arts. 280 and 281 are amended, part 8 is added to Art. 19, and in Art. 129 the rules on electronic service providers are extended to sellers of goods. The Law "On Electronic Commerce" No. ZRU-792 gains new definitions, a concept of cross-border trade, and new duties and liability for operators.

Three roles: who pays, who registers, who withholds

Under new part 1 of Art. 278 of the Tax Code, the VAT payer is a foreign legal entity that sells goods to individuals through electronic trading platforms where the place of supply is Uzbekistan. Under part 2, both the buyer's place of residence and the place of delivery must be in Uzbekistan. On a literal reading, a Tashkent resident who has goods delivered to Almaty, or a tourist who has a parcel sent to a hotel in Samarkand, falls outside the rule.

Who actually remits the tax depends on whose hands the buyer's money passes through. That is why some commentaries write about registering sellers, while some media headlines talk about "foreign marketplaces".

An Uzbek legal-entity intermediary that settles with individuals (for example, a payment agent) is also a tax agent under part 3, but it does not need to register under Art. 279. If there are several intermediaries, the agent is the one that settles both with the individuals and with the seller, even without a contract with the seller (part 4).

The main uncertainty concerns foreign platforms. Goods are named in the opening condition of part 3, but the part ends by referring to tax agents "in respect of transactions for the supply of such services". For goods, agent status follows expressly only from parts 4 and 5. KPMG takes the view that a foreign platform does not become an agent for goods, and that VAT stays with the seller if the chain has no intermediary caught by the general rule. Until clarifications are issued, it is worth securing your position with a written inquiry to the State Tax Committee.

Registering a non-resident: step by step

For providers of electronic services, registration under Art. 279 already works in a simplified form through an online service. According to the clarification issued by NAPP and the State Tax Committee in March 2026, it does not amount to registering a legal entity.

• Define your role for each sales channel. Find out who receives the buyer's money and who passes it on to you.
• Define the start date. The law does not say how to count the deadline for those who already sell into Uzbekistan; it is safer to count from 12 December 2026.
• Collect documents. The list for sellers of goods has not been published yet. Prepare the constituent documents and details of the director, and check the list on the filing date.
• Get access to the personal account. Under Art. 281, returns are filed electronically only.
• Set up sales accounting. For every sale, record the buyer's place of residence, the delivery address, the payment date, the amount and the currency.
• Report quarterly. If your sales under the regime begin in December, the first period is Q4 2026, with the return and payment due by 20 January 2027.
• Monitor incoming documents. Under new part 8 of Art. 19 of the Tax Code, documents sent to a non-resident are deemed received 30 days after dispatch.

Key parameters as of the publication date, October 2026, under Tax Code Arts. 258 and 280–281:

ZRU-1173 did not change the rules on the moment the base is determined, on currency conversion or on self-assessment of the tax, and literally they speak of services. Their application to goods should be confirmed with the State Tax Committee on the filing date.

A hypothetical example: goods are sold for UZS 1,120,000, tax included. Backing out VAT with the 12/112 formula gives VAT of UZS 120,000 and seller revenue before commission of UZS 1,000,000, so the tax takes about 10.7% of the buyer's price. The price is illustrative and unrelated to the cost of Pactum services, and the method of backing out the tax should be checked with the State Tax Committee.

An Uzbek platform as tax agent

Under Art. 278(5), the operator of an Uzbekistan-based electronic trading platform that processes payments in favor of a foreign seller is a tax agent for both goods and services. This is the standard marketplace model: the buyer pays the platform, and the platform passes the proceeds to the seller net of commission and, from 12 December, net of VAT as well.

If the non-resident does not raise prices, its revenue from every sale will fall by about 10.7%. The law does not detail how the tax is adjusted when goods are returned. This should be set out in the platform offer and checked against the general rules on VAT refund and credit. A checklist for platforms is in the plan below.

New requirements for platforms: what the law expressly says

From 12 December, ZRU-1173 also amends the Law "On Electronic Commerce". These changes affect every operator, even one with no non-resident sellers.

• Subsidiary liability (Art. 12). The seller is primarily liable to the buyer. If the seller cannot satisfy lawful claims, the operator is subsidiarily liable, unless the contract or legislation provides otherwise.
• Seller checks (Art. 13). The operator verifies sellers' licenses in licensed fields, does not allow the sale of confiscated or restricted goods, and protects personal data and payments.
• Transparency (Art. 13). Display and ranking algorithms must be transparent, reviews must not be altered, the rules and the offer must be published, and changes to the rules must be announced at least 30 days in advance.
• Returns (Arts. 16 and 27). The seller must disclose return terms, and an operator that holds the buyer's payment in escrow may itself refund the money if the seller refuses.
• Separate accounts (Art. 23). Operators, seller legal entities, individual entrepreneurs and self-employed persons settle only through separate bank accounts. Previously this requirement appeared only in para. 5 of Cabinet of Ministers Resolution No. 885.

If a non-resident seller with no assets in Uzbekistan cannot satisfy a buyer's claim, the operator will have to answer subsidiarily. The law allows the contract to provide otherwise, and, with consumer protection legislation in mind, this should be worked out in the platform offer together with a right of recourse against the seller. More in our analysis of marketplace and aggregator liability for sellers.

Background: the resident-entity requirement for platforms and the 2026 rates

It is often written that a resident legal entity has been mandatory for platforms since 1 July 2025. More precisely, para. 2 of Resolution No. 885 is worded as an endorsement of proposals by government agencies, but the government has applied it since 28 December 2024 (TEMU is the example). The date of 1 July 2025 was set in para. 3, but the working procedure was introduced by NAPP Order No. 24 from 24 September 2026: para. 4 of the regulation prohibits operating without notification, and para. 5(a) requires state registration as a legal entity of Uzbekistan. For a foreign platform this is above all a risk rather than an indisputable rule, and the position may change once the cross-border trade procedures are adopted (Art. 10¹ of ZRU-792).

Scenarios: how it works in practice

The examples are hypothetical and illustrate the logic of the law.

A Chinese seller on an Uzbek marketplace

A Chinese company sells electronics through an Uzbek marketplace to residents of Uzbekistan. The platform receives the payment and passes the proceeds to the seller net of commission. This is Art. 278(5): the platform calculates VAT from the sale price and withholds it from the payout, and the seller does not need to register. The question of importing the goods remains open; see the answer on double VAT below and the page on foreign trade and customs.

A Turkish brand selling through its own website

A clothing brand accepts payment on its own website and ships parcels to Uzbekistan. The first question is whether its own online store counts as an electronic trading platform under ZRU-792. If it does, the brand registers itself and pays 12% quarterly. If a payment provider receives the money under an agency agreement, the provider may be the agent under part 3. The alternative is to import goods in batches into its own company in Uzbekistan; the choice is made by calculation on real volumes.

A foreign platform with no entity in Uzbekistan

A marketplace from another country receives payment from Uzbek buyers for goods of third-party sellers. If it does so under an agency or commission agreement with the sellers, it may be treated as a tax agent under Art. 278(3): in that case it registers and withholds VAT itself. But because of the gap in the wording of part 3, the obligation may remain with the sellers, so it is worth preparing registration for both variants and sending an inquiry to the State Tax Committee. Localization is a separate question: NAPP Order No. 24 requires the operator to file a notification and to be a legal entity of Uzbekistan.

60-day plan

For a foreign seller

• By the end of October, identify orders from individuals with delivery to Uzbekistan and determine who receives the payment.
• Recalculate prices and ask the platforms for a new offer and the VAT withholding procedure.
• If you settle with buyers yourself, prepare the documents and personal-account access by the end of November.
• Review the import scheme and the risk of double VAT.
• From 12 December, file the application within the established deadline and keep a register of sales by quarter.

For a platform

• Flag non-resident sellers and the payout scheme for each of them.
• Prepare the offer: tax agent status, VAT withholding, data to be provided by the non-resident, a report on withholdings, recourse for buyers' claims.
• Publish the new rules no later than 11 November 2026, and preferably by early November. The 30-day announcement rule in Art. 13 of ZRU-792 itself applies from 12 December, but such a margin is sensible caution.
• Upgrade billing: non-resident flag, place of supply, tax breakdown, payment date, Central Bank rate, returns.
• Check separate bank accounts, license checks, disclosure of return terms and the notification under NAPP Order No. 24.
• Appoint a person responsible for tax agent duties.

What has not been adopted yet and where to look

As of 12 October 2026, three groups of documents are still missing:

• A Cabinet of Ministers resolution on cross-border e-commerce procedures. Under Art. 4 of ZRU-1173 it must be adopted within three months of the law's publication, that is, by 11 December 2026. We have not yet found a draft.
• A State Tax Committee list of documents for registering sellers of goods.
• Alignment of government decisions with the law. Art. 4 requires it but sets no deadline; it will probably affect Resolution No. 885 as well.

Monitor lex.uz and regulation.gov.uz.

How Pactum helps

• We analyze settlement schemes and record your company's role in writing: payer, tax agent, or sales outside the regime.
• We prepare the non-resident's registration under Art. 279, an inquiry to the State Tax Committee on disputed points, and a reporting calendar.
• We rewrite the platform offer, seller agreements and platform rules for ZRU-1173.
• We compare selling as a non-resident with selling through a local company and, where needed, register an LLC (from UZS 3,500,000).
• We review the customs part of the chain and the risk of double VAT.

You can start with a lawyer consultation: 60 minutes, UZS 300,000, credited toward the cost of the service; ongoing support is priced after we review the task. More on our tax compliance in Uzbekistan page.

FAQ

Does a foreign seller need to set up a company in Uzbekistan?

Not for VAT: registration under Art. 279 is a tax registration and does not mean registering a legal entity. A local company is usually required, or more advantageous, if you want to operate as a platform yourself (NAPP Order No. 24 requires the status of an Uzbek legal entity) or to hold and sell stock inside the country, since otherwise there is a risk of a permanent establishment. You can also sell through a local commission agent, so the option is chosen after a calculation.

How do you pay Uzbek VAT from abroad?

The return is filed electronically through the personal account by the 20th of the month after the quarter, and the tax is paid by the same deadline. The currency conversion at the Central Bank rate in Art. 280 is literally written for electronic services, and its application to goods needs to be confirmed with the State Tax Committee. Technical payment details have not been published yet.

What happens if you do not register or do not pay the VAT?

The Tax Code provides for a fine for non-payment (Art. 224), late-payment interest (Art. 110), liability for violating the registration procedure (Art. 219) and for late reporting (Art. 220). How these will be applied to non-residents under Chapter 39 will be shown by practice, so the amount cannot be stated in advance. A foreign platform with no local legal entity also faces restricted access, as was announced for TEMU in 2025.

Does the new VAT apply to sales to businesses?

On a literal reading, probably not: parts 1–2 of Art. 278 speak of sales to individuals. But part 5, on Uzbek platforms, is worded more broadly, and B2B sales through them should be checked until clarifications appear. For services provided to Uzbek legal entities, the buyer itself becomes the tax agent under part 6.

Will VAT be charged twice, on import and on the sale?

The law does not regulate this question, as KPMG also points out. Parcels to individuals within the duty-exempt allowance, parcels above the allowance, and batch imports into a local legal entity with import VAT paid at customs are taxed differently. If import VAT has been paid and the platform also withholds VAT on the sale, the risk of double taxation is real. Check the duty-exemption thresholds on the import date.

How can a platform confirm that the buyer lives in Uzbekistan?

The law does not say how to confirm the buyer's place of residence. It makes sense to start collecting the country of residence and the delivery address when the order is placed. This is personal data processing; more on the page about personal data in Uzbekistan.

Sources

• ZRU-1173 of 10 Sep 2026 (official text, in Uzbek)
• Tax Code, current version
• Tax Code as worded on 25 Dec 2025
• Law "On Electronic Commerce" No. ZRU-792
• Cabinet of Ministers Resolution No. 885 of 26 Dec 2024
• NAPP Order No. 24 (reg. No. 3927 of 19 Aug 2026) on notification of e-commerce operators
• NAPP and State Tax Committee, 4 Mar 2025: restriction of TEMU
• NAPP and State Tax Committee: clarification for providers of electronic services, March 2026 (PDF)
• KPMG, 21 Sep 2026: Uzbekistan VAT on non-resident e-commerce sellers
• Buxgalter.uz, 14 Sep 2026: "Who will pay VAT for a foreign seller on a marketplace: changes to the Tax Code" (in Russian)
• Spot.uz, 14 Sep 2026: "Marketplaces and streaming services must make their algorithms transparent" (in Russian)