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Banking & Finance Law

Tashkent International Financial Centre (TIFC): Participants, Tax Benefits to 2076 and Visas of Up to 5 Years

The Constitutional Law on the Tashkent International Financial Centre has been in force since 25 July 2026. An article-by-article review: English law, the TFSA regulator and the TICC court, tax benefits to 2076 for financial companies and holdings, visas of up to 5 years, and the deadlines for TIFC…

Pactum Legal Team
Pactum Legal Team
Pactum Corporate Practice
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The Tashkent International Financial Centre (TIFC) is a special jurisdiction in Tashkent with its own acts in English, the common law of England and Wales, the TFSA financial regulator and the Tashkent International Commercial Court (TICC). Constitutional Law No. ZRU-1158 of 13 July 2026 has been in force since 25 July 2026: it exempts qualified participants from corporate income tax and social tax on income from financial services until 1 January 2076, allows entry visas of up to 5 years and lets participants hire qualified foreign nationals without confirmation of their right to work. As of the publication date (October 2026), we found no published TIFC acts on participant registration and licensing, and no activation date has been announced; Decree UP-188 of 10 September 2026 sets 1 December 2026 as the deadline for the first key decisions, and the centre is officially expected to start operating in 2027.

Key points

  • The law is in force; the centre is not yet. ZRU-1158 has applied since 25 July 2026. TIFC acts must be adopted within 12 months, extendable by up to 6, after which the President confirms the activation date (Art. 31).
  • English law and language. After the Constitution, the law, presidential decrees and TIFC acts, the common law of England and Wales applies; the working language is English (Arts. 8 and 30).
  • Tax benefits until 1 January 2076. Corporate income tax and social tax — for qualified participants on income from financial services, provided they have real economic presence in the centre. Separately — income of non-resident employees, listed securities and shares in TIFC participants, and customs duties (Art. 18).
  • A holding company is not a financial company. It can use the exemptions for dividends and for income from stakes in TIFC participants, but not the exemption for profits (Art. 18(3) and (9)).
  • Large groups get no corporate income tax benefit. At group revenue of EUR 750 million or more, the QDMTT top-up tax applies instead (Art. 19).
  • Staff. Visas of up to 5 years and hiring without a work permit (Arts. 20 and 21) will start working after the TIFC acts are adopted; salaries are exempt only for tax non-residents.

Abbreviations: UP — Presidential Decree; ZRU — Law of the Republic of Uzbekistan (shown as LRU in the English text on lex.uz); TFSA — Tashkent Financial Services Authority; TICC — Tashkent International Commercial Court; QDMTT — Qualified Domestic Minimum Top-up Tax; AML/CFT — anti-money laundering and countering the financing of terrorism.

What changed in 2026

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DateEvent
30 March 2026Decree UP-48 establishing the TIFC and the Tashkent International Commercial Court; a $20 million grant for 2026
1–16 April 2026The draft law is put out for consultation by the Ministry of Investment, Industry and Trade
2–13 June 2026The Legislative Chamber adopts the law in the second and third readings; the Senate returns it to a conciliation commission for revision
1 and 9 July 2026The Chamber re-adopts the law and the Senate approves it; the law's date on lex.uz is 13 July 2026
25 July 2026The law enters into force; the 12-month period for TIFC acts begins
18 August 2026The President's press secretary: the TIFC will start operating in 2027
10 September 2026Saida Mirziyoyeva is appointed Governor of the TIFC and Secretary General of the Board; Decree UP-188 on organisational measures is signed, in force from 11 September 2026

According to media reports, the centre will be located in the Tashkent City complex (spot.uz, in Russian); once operations begin, its boundaries can only be enlarged, not reduced (Art. 3).

Article 8 sets the hierarchy of applicable law:

  • The Constitution of the Republic of Uzbekistan.
  • The Constitutional Law on the TIFC.
  • Presidential decrees — on matters the law expressly reserves for them.
  • TIFC acts.
  • The common law and equity of England and Wales — to the extent they do not conflict with the higher sources.

TIFC acts prevail over conflicting national legislation, except for the Constitution, the law itself and ratified treaties, and transactions in or through the centre are governed by TIFC acts unless the parties agree otherwise. However, Article 12 keeps in force within the centre, among other things, criminal, administrative (with the exceptions in Art. 12(2)), immigration, family and environmental law, and legislation on security, AML/CFT, emergencies and public health.

  • Language (Arts. 9 and 30). A TIFC act takes effect only after it is published in English in the Official Register of TIFC Acts. Proceedings in the TICC and written transactions are in English unless the parties agree otherwise.
  • Currency (Art. 17). Obligations can be performed in foreign currency, including digital assets; most national currency-control requirements do not apply, and TIFC acts must implement the principle of unrestricted capital repatriation. For the regime outside the centre, see our review of currency control and repatriation of proceeds.

TIFC bodies: who registers, licenses and rules on disputes

Four bodies operate independently, and the state is not liable for their obligations (Art. 22).

BodyWhat it doesArticles
BoardAt least 5 members, chaired by the President; approves participant requirements and registration procedures; the Secretary General is the Governor of the TIFCArts. 5, 25, 26
TIFC AuthorityExecutive body; registers holding companies, private foundations, trusts, corporate service providers and representative offices; keeps records of foreign employeesArts. 7, 21, 27
TFSALicensing and supervision: financial services, market infrastructure, digital assets; regulatory sandboxArts. 7, 28
TICCCourt of first instance and appeal; judges of any nationality; appeal decisions are final; all judgments are published within 30 daysArt. 29

Who can become a TIFC participant and what permission is required

Under Article 5, legal entities established under foreign law, Uzbek law or TIFC acts can become participants if they meet the requirements set by Board acts. A participant offers services to persons in Uzbekistan outside the centre only in compliance with the national rules on finance, taxation and securities.

Type of activityWho grants permissionWho needs it
Regulated financial services (15 types): banking, deposits, brokerage, payments, fund and trust management, insurance, crowdfundingTFSA: licence, registration or exemptionBank, insurer, asset manager, broker, multi-family office
Market infrastructure: clearing, custody, depositories, exchangesTFSAExchange and settlement projects
Digital assets: issuance, trading, custody, funds and exchangesTFSACrypto exchange, custodian, tokenisation platform
Other permitted activities: holding companies, private foundations, trusts, corporate services, representative officesTIFC AuthorityGroup holding company, family structure holding its own assets

Registration with the Authority suits a holding company or a single-family structure that holds its own assets. If a family office manages the assets of third parties or of several families, or acts as a trustee, this is a regulated financial service and TFSA permission is required (Art. 7(1)). The law sets no deadlines for reviewing applications.

TIFC tax benefits until 1 January 2076

Article 18 has to be read paragraph by paragraph: the date "until 1 January 2076" does not apply to every benefit. The Tax Committee published a summary of the benefits on 16 July 2026 (gov.uz, in Russian).

BenefitWho or what is exemptTermProvision
Corporate income tax and social taxTIFC bodies; qualified participants on income from financial services; income from ancillary servicesuntil 1 January 2076Art. 18(2), (3), (6)
Tax on employees' incomeNon-resident employees; residents may be exempted under a procedure that has not yet been establisheduntil 1 January 2076Art. 18(8)
Tax on income and capital gainsSale of listed securities and of shares and stakes in participants; dividends on listed securities and from participants; foreign-source income of investment tax residentsuntil 1 January 2076Art. 18(9)
Customs duties and leviesGoods for use in the TIFC; duties are payable on removaluntil 1 January 2076Art. 18(16)
Property tax and land taxReal property of TIFC bodies and participants in the TIFCno term statedArt. 18(12)
VATServices and activities of participants carried out in accordance with the lawno term statedArt. 18(14)

Later legislation cannot reduce the benefits without the consent of the Board. The first review of the benefits takes place within 10 years of the law's entry into force and every 5 years after that; a review does not in itself mean any change.

Who is a qualified participant

The exemption under Art. 18(3) goes only to a participant that has sufficient economic presence (substance) in the TIFC, earns income from financial services provided from the centre or exported from it, and meets the requirements of the Authority's acts, including separate accounting. Otherwise taxes are paid under the Tax Code. Digital asset exchanges that lack economic presence, corporate governance, AML/CFT, counter-proliferation financing and cybersecurity do not receive this benefit.

Holding company, family office and IT company: which benefits apply

Registration with the Authority does not make a participant qualified. A holding company receives the exemptions under Art. 18(9) — income from the sale of stakes in TIFC participants and of listed securities, and dividends from TIFC participants — as well as the VAT and property tax exemptions. Art. 18(9) does not cover dividends from operating companies outside the centre or from foreign subsidiaries; their treatment depends on TIFC acts (Art. 18(1)). IT and fintech companies can operate in the centre under Art. 7(5), but the profit exemption in Art. 18(3) does not apply to them.

Exception for large groups: EUR 750 million and the QDMTT

Article 19 denies the income tax benefits to participants that belong to international groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding years: instead, the group pays the QDMTT at the standard corporate income tax rate of Uzbekistan. Article 19 does not expressly exclude the exemptions for VAT, property, customs and the income of non-resident employees — whether they apply to a group is checked against the Board act on the QDMTT. For such groups, the main attraction is English law, the court and the visas.

TIFC Investment Tax Resident

Article 13 introduces a status for individual investors, their spouses and children under 18. The applicant must not have been a tax resident of Uzbekistan during the 3 years before applying, and the applicant's Uzbek citizenship, if any, must not have been terminated during the 10 years before applying. The forms and amount of investment will be set by a Board act; the law sets no minimum amount. The status will be refused if its main purpose is tax avoidance, and applicants may be required to disclose beneficial owners, the source of funds and their sanctions status.

Since 1 January 2026, a special tax regime for foreigners has operated in parallel under Decree UP-180 of 4 October 2025:

ParameterTIFC Investment Tax ResidentUP-180 special regime
What is exemptForeign-source income until 1 January 2076Personal income tax (PIT) on income from abroad
Fee for the statusA mandatory payment; the amount will be set by a TIFC Authority actA fee of $50,000, and $10,000 for each adult close relative
AlsoVisas of up to 5 years, access to the TICC and its wills registerRegistration at the place of stay for up to 5 years
When availableAfter the TIFC acts and activationFrom 1 January 2026

According to media reports, in July 2026 the Legislative Chamber adopted a law on this regime — check its status and conditions on the filing date.

Staff: visas of up to 5 years and hiring without a work permit

Under Article 20, a TIFC person and the members of his or her family can obtain entry visas of up to 5 years, extendable without leaving the country on the application of the Authority. Under Article 21, participants hire qualified foreign nationals without confirmation of the right to work, and a work permit is not needed where the employee's principal place of work is in the centre; the requirements and quotas will be set by the Authority.

These rights will start working only after the TIFC acts are adopted and the centre is activated: the entry procedure is set by a Board act (Art. 20(5)), and drafts on visas and simplified migration registration are being prepared under clause 7 of UP-188. Salaries are exempt only for tax non-residents (Art. 18(8)). An employee who spends more than 183 days in Uzbekistan in any 12 consecutive months becomes a tax resident (Art. 30 of the Tax Code), and the procedure for exempting residents has not yet been established.

Liability and asset protection

A participant can be fined up to the greater of $10 million or 10% of the value of the transaction (Art. 16). Assets in the TIFC or created under TIFC acts are protected against confiscation, nationalisation and attachment, except under a final decision of the TICC and restrictions relating to AML/CFT, sanctions, criminal proceeds and insolvency (Art. 6).

What has not yet been adopted and how the launch will work

  • TIFC acts are to be adopted no later than 12 months after the law takes effect; the Board may extend this period by no more than 6 months (Art. 31).
  • The Board announces that the centre is ready, the President confirms, and the activation date falls no later than one month after the confirmation.
  • Only during the transitional period do holders of national licences provide in the centre the services covered by their licence without a new application, and within 60 days they register a subsidiary or a branch (Art. 32).
  • The Board determines the eligible foreign jurisdictions and regulators, and the TFSA reviews the applications: where a supervisory memorandum is in force — a transitional licence; while a memorandum is being agreed — an interim licence at the Board's discretion for up to 6 months (if the standards are comparable and FATF standards are met), extendable once by up to 5 months; registration with the Authority — no later than 60 days (Art. 33).

UP-188 sets the nearest deadlines: the first Board meeting within two months of the decree's publication; by 1 December 2026 — 10 TIFC decisions, including the investment tax residency programme, the tax benefits and the requirements for qualified participants, and tax and customs administration; within three months — drafts on visas and migration registration. These are the decree's deadlines, not a guarantee of launch. By our calculation, the Article 31 period expires at the end of July 2027 and, with an extension, no later than the end of January 2028; this is an inference from dates, not a rule of law. The official guidance is 2027 without a month (Interfax), so check the published acts on the filing date.

How to prepare for entry now

  • Determine whether a TFSA licence is needed or registration with the Authority is enough (Art. 7).
  • Compare the group's revenue with the EUR 750 million threshold (Art. 19).
  • If you need a financial business before the launch, obtain a national licence (financial licences, crypto licence): under Article 32 it gives transitional access to the centre.
  • Plan the substance: an office, management and decision-making staff in the centre.
  • Assemble a disclosure package: beneficial owners, source of funds, tax residency, sanctions checks.

TIFC, IT Park or a regular LLC

CriterionTIFCIT ParkRegular LLC
Best suited toBanks, insurers, asset managers, brokers, digital assets; holding companies and family structuresIT companies, software exportsTrade, manufacturing, services
Taxes: financial companiesProfit exemption until 1 January 2076 for qualified participants; groups with EUR 750 million or more — QDMTTBenefits for IT activities onlyGeneral regime
Taxes: holdings and ITDividends and stakes of TIFC participants, listed securities (Art. 18(9)), VAT, property; Art. 18(3) does not applyPreferential regime for residents, check on the filing dateGeneral regime
DisputesTICC, in EnglishCourts of Uzbekistan, arbitration, or the TICC by agreement (after launch)Same
Foreign staffVisas of up to 5 years, no work permit — after activationGeneral rules with simplifications for ITGeneral rules
When you can startExpected in 2027NowNow

Until the centre launches, IT and fintech companies can start with IT Park residency and other businesses with a regular company, and then enter the TIFC through a subsidiary structure. LLC registration with Pactum lawyers starts from UZS 3,500,000; details are on the company registration page.

Example: an asset manager sets up a fund in Tashkent

The scenario is illustrative. An asset management company from the Persian Gulf, with group revenue of about $40 million, wants to run from Tashkent a fund investing in listed securities of Uzbek issuers and to relocate five employees with their families.

  • Permission. A TFSA licence is required; a transitional licence is possible if the Board recognises the company's regulator and a supervisory memorandum is in place.
  • Taxes. The Article 19 threshold is not reached, so the profit exemption is possible — subject to qualified participant status and real economic presence.
  • Team. Visas and hiring — after activation. Salaries are exempt while an employee remains a tax non-resident; those who relocate for a long period are likely to become residents — check their regime under the TIFC acts on the date of hiring.
  • Where the project breaks. If decisions are made in Dubai and Tashkent is only an address, the benefit is lost.

Common mistakes

  • Assuming the benefits come with an address in Tashkent City. They are tied to participant status and economic presence.
  • Treating a holding company as a qualified participant. A holding company receives the Art. 18(9) benefits, not the profit exemption.
  • Applying the 2076 date to all taxes. For VAT, property and land, the law names no term.
  • Promising the team a tax exemption on salaries. The exemption covers only tax non-residents.

How Pactum helps

  • We assess applicability: a TFSA licence, the Article 19 threshold, the benefits for your structure.
  • We design the entry structure and compare it with IT Park and a regular company.
  • We prepare the disclosure package for the participant and for the investment tax resident.
  • We track the acts of the Board, the Authority and the TFSA up to the activation date.
  • We support the relocation of staff: visas, records of foreign employees, employment contracts.

You can start with a lawyer consultation: 60 minutes, UZS 300,000, credited toward the cost of the service — book a consultation. The price of a TIFC entry project is given after we review your task; for related questions, see the page on foreign investment in Uzbekistan.

FAQ

When will the TIFC start registering participants?

After the mandatory acts are adopted, the Board announces that the centre is ready and the President confirms the activation date (Art. 31). UP-188 requires the first 10 TIFC decisions, including the requirements for qualified participants, to be adopted by 1 December 2026, but that is the decree's deadline, not a guarantee. As of the publication date (October 2026), no activation date has been announced, and the launch is expected in 2027.

Can an existing Uzbek company be moved into the TIFC?

There is no transfer mechanism. An Uzbek legal entity can itself become a participant (Art. 5), and a holder of a national licence, during the transitional period and only for the services covered by that licence, works in the centre without a new application, registering a subsidiary or a branch within 60 days (Art. 32).

Does a crypto company need a licence in the TIFC?

Yes: issuance, trading and custody of digital assets, as well as digital asset funds and exchanges, require TFSA permission (Art. 7). How the crypto market is regulated outside the centre is covered in our article on crypto assets and mining in Uzbekistan.

Which disputes does the TICC hear, and can it be chosen in a contract?

The TICC has exclusive jurisdiction over civil and employment disputes between TIFC persons, insolvency, and challenges to decisions of TIFC bodies; other parties can choose it by agreement. The court recognises and enforces arbitral awards from any state. For guidance on when to choose arbitration, see our article on international arbitration for Uzbek companies.

Can I become a TIFC investment tax resident now?

Not as of October 2026: the investment, the payment and the periods of stay will be set by TIFC acts. Under UP-188, a decision on the investment tax residency programme must be adopted by 1 December 2026, but that is not the date applications open. If you need to exempt foreign income now, consider the UP-180 regime.

How much does it cost to become a TIFC participant?

The law sets no amounts: TIFC bodies charge fees for licences, registration, permits and services (Art. 23), and the amounts will be set by TIFC acts — check them on the filing date. The work of Pactum lawyers on an entry project is priced after we review your task.

Sources

The acts cited are official texts on lex.uz, which are published in Uzbek and, for many acts, in Russian; the Constitutional Law is also available there in English. Descriptions of Russian- and Uzbek-language sources in this article are our own translations. The information is current as of October 2026.

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