Priced by scope of work

Tax audit and tax dispute in Uzbekistan

We act from the first notice to the court judgment: objections to the audit report, appeals against additional assessments, unfreezing bank accounts.

Discuss your case How it works

10 days to file written objections to the audit report
Pre-trial appeal is no longer mandatory — the rule was removed in 2024
A complaint suspends collection, but only if you notified the inspectorate

In brief

What should you do when a tax audit report arrives with an additional assessment?

Under article 156 of the Tax Code of Uzbekistan, written objections to a tax audit report are filed within 10 days of receiving it — the cheapest and most effective stage of the dispute, because arguments not raised here have to be proven in court later. Signing the report does not mean agreeing with the conclusions in it. Since 20 February 2024, mandatory pre-trial appeal against audit decisions has been abolished: part 4 of article 231 of the Tax Code was removed by Law ZRU-910, so a company may go straight to the administrative court. Filing a complaint suspends enforcement of the decision, but only if the taxpayer has notified the tax authority of this in writing.

Where money is lost

What usually goes wrong

These are not abstract risks but the scenarios that break deals and turn decisions of state authorities against you.

The audit begins before any audit — with a notice in your online tax account

Failing to comply within the time allowed is itself a ground to order a desk audit, followed by a demand to make corrections and, if your explanation falls short, a tax audit.

Common mistake: Since 1 January 2026 pre-audit analysis applies: reporting is analysed automatically by the tax authorities' information systems, without an order from the head of the authority and without the taxpayer taking part. The notice of a discrepancy lands in the online tax account, and the accountant learns about it when the response deadline is already running.

"A field audit is ten days, they won't assess anything anyway"

A ten-day audit you did not prepare for now produces a full decision on additional assessment with interest and a fine, followed by a collection order against your bank accounts.

Common mistake: The rule barring tax from being assessed on the results of a field audit was repealed by Law ZRU-758 of 11 March 2022. Companies still treat a field audit as a formality because they remember the old rule.

The ten days for objections are spent thinking it over

The company arrives at the hearing on the audit materials with no written position and no documents attached. The same dispute then costs several times more and is run from a weaker position.

Common mistake: The director signs the report assuming the signature settles nothing — and formally that is true, signing the report does not mean agreeing with it. But the objection period runs from the day the report was received, not from the day the company gets around to it.

The 50% discount on the fine is sold as a benefit

The fine really is halved if guilt is admitted and payment is made voluntarily within ten days. But admitting guilt closes off the appeal and creates a document that works against the company afterwards.

Common mistake: Accounting works out only the arithmetic of the saving and talks the director into signing. Nobody works out the other half of the equation — being held liable as a precondition for a later criminal classification.

Accounts are frozen by one person's decision

Outgoing payments stop: salaries, suppliers, loan instalments, customs clearance. The cash gap and the penalties under contracts usually exceed the tax dispute itself.

Common mistake: The grounds are mundane — reporting not filed, documents not produced. The decision is taken by the head of the tax authority, and the company hears about the freeze from its bank rather than from the inspectorate.

A month burned on a complaint that never had to be filed

While the administrative ladder runs its course, the deadline for going to court is ticking, and the higher authority upholds its subordinates' decision in the vast majority of cases.

Common mistake: Mandatory pre-trial appeal was removed from part 4 of article 231 of the Tax Code by Law ZRU-910 of 20 February 2024. A large share of advisers and websites still repeat the repealed rule.

The complaint was filed and the money was debited anyway

The inspectorate carries on with enforcement: a demand to settle the arrears, a collection order against the accounts, then enforcement against assets.

Common mistake: Filing a complaint suspends enforcement of the decision, but the law separately requires the taxpayer to notify the tax authority whose decision is being appealed, in writing, enclosing a copy of the complaint. Without that notice there is no suspension.

Outcome

What you get

Support during the audit

We draft responses to demands, keep track of the deadlines and the scope of documents requested, and record procedural breaches.

Written objections to the report

A position backed by calculations and documents within the ten-day period — the stage where the dispute is won at the lowest cost.

Attendance at the hearing

We represent the company when the report and the objections are considered, rather than sending the director to explain alone.

Appeal against the decision

We choose the route — the higher authority or straight to the administrative court — and file the written notice without which collection does not stop.

Unfreezing bank accounts

We remove the ground for suspending operations and secure its cancellation, so the business does not stall while the dispute runs.

Criminal risk assessment

We calculate the amount in base calculation values before anyone signs an admission of guilt for the sake of a discount on the fine.

How we work

How it works

01same day
Urgent assessment
We look at what actually arrived: a pre-audit analysis notice, a demand, an audit order, or the report itself. The deadlines already running depend on that.
02within 10 days of the report
Position and documents
We gather the evidence and cost out the disputed episodes, separating what can be defended from what is cheaper to pay.
03per Tax Code deadlines
Objections and hearing
We file the written objections and represent the company when the audit materials are considered.
04per appeal deadlines
Appeal
The higher authority or the administrative court — with written notice to the inspectorate so that collection is suspended.

Legal basis

What the law says

Every point links to the primary source so you can check it yourself.

The Tax Code provides for a desk tax audit, a field tax audit and a tax audit (art. 137 of the Tax Code).
lex.uz — Tax Code art. 137
Tax audits are not carried out in respect of business entities in the "AAA" category of the high sustainability rating, subject to certain exceptions (art. 137 part 4 of the Tax Code).
lex.uz — Tax Code art. 137
Pre-audit analysis is the automated analysis of reporting by the tax authorities' information systems, without an order from the head of the authority and without the taxpayer taking part (art. 138 of the Tax Code, wording in force from 1 January 2026).
lex.uz — Tax Code art. 138
Following a desk audit, a demand to make corrections is issued; the taxpayer must submit amended reporting or a justification of the discrepancies within five days (art. 138 of the Tax Code).
lex.uz — Tax Code art. 138
A field tax audit is carried out on the basis of an order of the head of the tax authority and lasts no more than ten days (art. 139 of the Tax Code).
lex.uz — Tax Code art. 139
The rule stating that no tax is assessed on the results of a field tax audit was repealed by Law ZRU-758 of 11 March 2022.
lex.uz — Tax Code
A tax audit is carried out in respect of high-risk taxpayers; notice is sent at least 30 calendar days before it begins (art. 140 of the Tax Code).
lex.uz — Tax Code art. 140
A tax audit lasts no more than 30 days, extendable to two months and in exceptional cases to three; the overall period may not exceed six months (art. 141 of the Tax Code).
lex.uz — Tax Code art. 141
Written objections to a tax audit report are submitted within ten days of receiving it; signing the report does not mean agreeing with the conclusions set out in it (art. 156 of the Tax Code).
lex.uz — Tax Code art. 156
The fine is halved where guilt is admitted and the financial sanctions are paid voluntarily within ten days of receiving the decision (art. 218 of the Tax Code).
lex.uz — Tax Code art. 218
Suspension of operations on bank accounts is decided by the head or a deputy head of the tax authority for a period of up to ten days (art. 111 of the Tax Code).
lex.uz — Tax Code art. 111
Mandatory pre-trial appeal against decisions on field audits and tax audits was removed from part 4 of article 231 of the Tax Code by Law ZRU-910 of 20 February 2024.
lex.uz — Tax Code art. 231
Filing a complaint with a higher authority or with a court suspends enforcement of the decision, and the taxpayer must notify the tax authority whose decision is being appealed, enclosing a copy of the complaint (art. 231 part 3 of the Tax Code).
lex.uz — Tax Code art. 231
Criminal liability for tax evasion is established by article 184 of the Criminal Code; the thresholds are set in base calculation values.
lex.uz — Criminal Code art. 184

Choosing an option

Where to appeal a decision of the tax authority

What we compare	Higher tax authority	Administrative court
Is this stage mandatory	No — the requirement of mandatory pre-trial appeal was removed from the Tax Code in February 2024	You may apply directly
Who decides	The same authority within the system whose decision is being appealed	An independent court
Cost	Lower — no state duty	Higher: duty plus running the case in full
Suspension of collection	Happens on filing the complaint, but only after written notice to the inspectorate	The same — notice is mandatory
When it is chosen	A procedural or arithmetical dispute, with a chance to drop the episode without going to court	A dispute on the merits and on how the rule is interpreted

The administrative stage is no longer a compulsory gateway to court. It makes sense where the error is obvious and cheaper to remove inside the system; where the dispute is about interpreting the rule, the month spent on a complaint is wasted.

Next step

Tell us about your case

We will go through your situation, tell you what can realistically be done and by when, and name a price once we understand the scope. Any figure before that would be made up.

Phone: +998990505070

Telegram: @pactum_uz

Email: info@pactum.uz

Согласен на обработку персональных данных и с политикой конфиденциальности.

Консультация по задаче — бесплатно. Стоимость работы называем после того, как поймём объём.

Questions

Frequently asked questions

How long do you have to object to an audit report?

Ten days from the day the report is received, under art. 156 of the Tax Code. This is the key deadline: arguments and documents not put forward at this stage have to be proven in court later, where the dispute costs considerably more.

Do you have to complain to the higher authority first?

No. Part 4 of art. 231 of the Tax Code, which required mandatory pre-trial appeal against decisions on field audits and tax audits, was removed by Law ZRU-910 of 20 February 2024. You can apply to the administrative court directly.

Does a complaint suspend collection of the additional assessment?

Yes, with one condition. Under art. 231 part 3 of the Tax Code, filing a complaint with a higher authority or with a court suspends enforcement of the decision, but the taxpayer must notify the tax authority whose decision is being appealed in writing, enclosing a copy of the complaint. Without that notice, collection orders go to the bank.

Is it worth admitting guilt for the 50% discount on the fine?

That decision is worked out as a whole, not from the arithmetic of the fine. Under art. 218 of the Tax Code the fine is halved where guilt is admitted and payment is made within ten days, but the admission closes off the appeal and stays on file as the fact of having been held liable. The decision is taken after assessing the amount in base calculation values.

Can tax be assessed following a field audit?

Yes. The rule barring tax from being assessed on the results of a field audit was repealed by Law ZRU-758 of 11 March 2022. Today a ten-day field audit ends in a full decision with an additional assessment, interest and a fine.

For how long can bank accounts be frozen?

Suspension of operations on bank accounts is decided by the head or a deputy head of the tax authority for a period of up to ten days (art. 111 of the Tax Code). The grounds are often procedural — failure to file reporting or produce documents, for example — so the freeze is frequently lifted by removing the cause.

How long does a tax audit last?

No more than 30 days from the date the order is served, extendable to two months and in exceptional cases to three; the overall period may not exceed six months (art. 141 of the Tax Code). Notice of the audit is sent at least 30 calendar days before it begins.

What is pre-audit analysis and how do you find out about it?

It is the automated analysis of reporting by the tax authorities' information systems, carried out without an order from the head of the authority and without the taxpayer taking part (art. 138 of the Tax Code, in force from 1 January 2026). Where discrepancies are found, the notice is sent to the taxpayer's online tax account — which has to be checked regularly, because the response period runs from the moment it is sent.

Why this can be entrusted to us

Verifiable facts about us

No testimonials and no case studies here: they cannot be verified. Only what you can confirm yourself.

Every rule on this page comes with a link to the version of the Tax Code and the Criminal Code in force on lex.uz — deadlines in tax disputes change, and they should be checked against the primary source.
We state what the market repeats incorrectly: mandatory pre-trial appeal was abolished in February 2024, and the bar on assessing tax after a field audit was lifted back in March 2022.
Pactum is a legal services platform for Uzbekistan: 5042 services in the catalogue, and each request goes to a lawyer specialising in that area.

Related materials and services

Tax audits Tax advisory Court representation Buying a company or an LLC interest

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This material is for information only and is not legal advice on your particular situation. Rules and rates change — check the current wording via the links to the primary sources above. To have your case assessed, send a request.