Fee depends on the scope of work

Counterparty due diligence in Uzbekistan

We build the due diligence file that protects your deductible costs and your VAT credit, and cover by contract what no register will ever show.

  • Due diligence is a duty under article 15 of the Tax Code
  • From 1 January 2026 the VAT credit depends on the invoice risk category
  • Cancelling a supplier's VAT certificate hits its buyers as well
In short

Why check a counterparty in Uzbekistan, and what is at stake if you do not?

Checking a counterparty in Uzbekistan is not good practice, it is a duty: part one of article 15 of the Tax Code requires a taxpayer to exercise due diligence when selecting counterparties, verifying their tax registration, business reputation, production facilities and staff, financial standing and ability to perform the obligations under the transaction. Part two of the same article states plainly that costs under transactions with persons who have failed to perform their obligations are not recognised for tax purposes if the taxpayer did not exercise due diligence when entering into the transaction. Separately, from 1 January 2026 VAT on an invoice assigned to the high-risk category cannot be credited by the buyer.

Where money is lost

What usually goes wrong

These are not abstract risks but the scenarios that break deals and make state authorities decide against you.

The invoice arrives in a risk category and the VAT credit fails

The tax was paid to the supplier as part of the price, yet it cannot be credited and lands on your margin. On regular purchases the quarterly amount adds up to something comparable to your profit.

Typical mistake: People assume that once an invoice is issued and signed the credit is guaranteed. From 1 January 2026 part two of article 267 of the Tax Code prohibits crediting VAT on an invoice assigned to the high-risk category, except where the tax is paid under the procedure of article 266-1.

The tax authority disallows the costs a year later and there is nothing to prove the check

Additional tax on the entire amount disallowed plus late-payment interest for the whole period. A commercial loss on the deal turns into a tax loss and doubles.

Typical mistake: The check was done verbally. A due diligence file has to be written and dated the day the transaction was concluded, not the day the audit arrived.

The supplier's certificate is cancelled and your credit falls away too

A retrospective adjustment for periods already closed: additional VAT and interest. The goods are sold, the money is spent, and recovering the tax from the supplier is practically impossible.

Typical mistake: The counterparty was checked once, when the framework contract was signed. Yet on suspension, termination or cancellation of the certificate the tax is not credited at that supplier's buyers either — the status has to be checked for every delivery.

The advance has been paid and there is nothing at the supplier's address

The advance is lost in full, and your own obligations to your customer are missed. Enforcing against an empty company takes years and usually ends at zero.

Typical mistake: Only the fact of registration and the taxpayer number (STIR) were checked. The law also requires looking at production facilities and staff, financial standing and the ability to perform — none of which appears in any extract, and all of which calls for requesting documents and checking the facts on the ground.

The contract was signed by someone without authority

The counterparty claims the transaction does not bind it, money or goods are stuck, and enforcement runs into a dispute about whether the contract is valid at all.

Typical mistake: Nobody verified, as at the signing date, who the acting director was and whether liquidation had already started. Registration data on a legal entity is issued by taxpayer number free of charge and automatically, yet people usually look it up after the problem has happened.

Disqualified from a tender because of a subcontractor

The loss of that particular contract plus a reputational trace in the public procurement system that follows you into future tenders.

Typical mistake: The counterparty was checked as a supplier — taxes and registration — but its public procurement record was not. The register of unfair contractors is open, yet it is not on the accounting department's checklist.

A foreign company enters the market and looks for the tools it is used to

Either the deal stalls, or worse, it goes ahead with a false sense of security based on logic borrowed from another jurisdiction.

Typical mistake: People look for an equivalent of Russia's unified state register with a full extract, a Transparent Business service and an open case docket. The set of sources in Uzbekistan is different and noticeably narrower, and part of the data is issued only by taxpayer number and without financial indicators.

Deliverables

What you get

Due diligence file

A written report dated the day of the transaction, structured by the criteria of article 15 of the Tax Code — the document you put in front of an audit.

Checks against official registers

Registration data of the legal entity by taxpayer number, tax status, public risk lists, the register of unfair contractors in public procurement.

Signing authority check

Who may sign as at the date of the transaction, whether liquidation or reorganisation is under way, whether the authority matches the contract amount.

Assessment of the ability to perform

Production facilities, staff, licences and permits for the subject matter of the contract — what an extract does not contain.

Contractual protection

A tax clause, representations, payment mechanics and security — for the risks that registers cannot cover.

Procedure for repeat purchases

The routine by which your accounting department checks the status for every delivery rather than once per contract.

How we work

How it works

  1. 011 day

    Express screening

    Registration data by taxpayer number, tax status and public lists — this answers whether it is worth going any further.

  2. 023–7 days

    Extended check

    Requesting documents from the counterparty, signing authority, licences, encumbrances, public procurement record.

  3. 031–2 days

    File and conclusion

    A written report with a risk assessment and a recommendation: proceed, proceed with safeguards, or decline.

  4. 042–5 days

    Contractual protection

    We amend the contract for the risks identified and set up the checking routine for future deliveries.

Legal basis

What the law says

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

  • Taxpayers are obliged to exercise due diligence when selecting counterparties, verifying their tax registration, business reputation, production facilities and staff, financial standing and ability to perform the obligations under the transaction (part 1 of article 15 of the Tax Code).

    lex.uz — Tax Code, art. 15
  • Costs under transactions with persons who have failed to perform their obligations are not recognised for tax purposes if the taxpayer did not exercise due diligence when entering into the transaction (part 2 of article 15 of the Tax Code).

    lex.uz — Tax Code, art. 15
  • The VAT stated in an invoice assigned to the high-risk category is not credited by buyers, except where the tax is paid under the procedure of article 266-1 (part 2 of article 267 of the Tax Code as amended by ZRU-1108 of 25 December 2025, in force from 1 January 2026).

    lex.uz — Tax Code, art. 267
  • Where the certificate of registration as a VAT payer is suspended, terminated or cancelled, the tax is also not creditable at the buyers of such a supplier (part 1 of article 266-1 of the Tax Code, introduced by ZRU-812 of 30 December 2022).

    lex.uz — Tax Code, art. 266-1
  • When the certificate is reinstated, the credit is restored for the taxpayer and for its buyers as from the date of suspension (part 2 of article 266-1 of the Tax Code).

    lex.uz — Tax Code, art. 266-1
  • The procedure for determining the risk level of invoices, maintaining the register of such invoices and paying tax on their basis is established by the Cabinet of Ministers (part 8 of article 266-1 of the Tax Code).

    lex.uz — Tax Code, art. 266-1
  • VAT may be credited where there is an invoice with the tax amount stated separately and provided the supplier is registered as a VAT payer (item 2 of part 1 of article 266 of the Tax Code).

    lex.uz — Tax Code, art. 266
  • The tax authorities may change the legal qualification of a transaction if its sole or predominant purpose is to obtain an unjustified tax benefit; if the taxpayer disagrees, this is established by a court on the claim of the tax authority (article 14 of the Tax Code).

    lex.uz — Tax Code, art. 14
  • The public service “Access to the registration data of legal entities” is provided free of charge and automatically by taxpayer number; the data providers are the Ministry of Justice and the Tax Committee.

    my.gov.uz — public service No. 77
  • The Tax Committee published a list of 7 522 entities engaged in unofficial economic activity and doubtful transactions, and recommends requesting a counterparty's financial statements and confirming that its office and warehouse premises actually exist.

    Tax Committee, 13.10.2025
  • The register of unfair contractors is published on Uzbekistan's public procurement portal at xarid.uzex.uz/info/unfair-executor.

    xarid.uzex.uz — public procurement
Choosing an option

Three ways to run the check that a director chooses between

CriterionIn-houseAutomated report by taxpayer numberLegal due diligence
What it coversRegistration, registration data, public listsThe same, but pulled into a single document within minutesPlus the signatory's authority, licences, encumbrances, public procurement record, document analysis and the real ability to perform
Does it work as evidence of diligenceWeakly: a screenshot with no date and no conclusionPartly: there is a document, but it is incomplete against the criteria of article 15Yes: a written file structured by the statutory criteria and dated the day of the transaction
TimingHoursMinutes3–7 days
What stays uncoveredEverything that is not in the registersEverything that is not in the registersResidual risks are moved into the contract — tax clause, representations, security

An automated report answers the question “does this company exist”. The tax authority asks something else: did you check the counterparty's ability to perform this particular transaction. These are different checks, and the second one is done with documents, not with a button.

Next step

Tell us about your case

We will go through your situation, tell you what can realistically be done and in what time, and quote a fee once we understand the scope. Before that, any figure would be made up.

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

Questions

Frequently asked questions

Is checking a counterparty mandatory by law?
Yes. Part one of article 15 of the Tax Code expressly obliges taxpayers to exercise due diligence when selecting counterparties. This is not a recommendation: part two of the same article denies recognition of costs under transactions with persons who failed to perform their obligations if due diligence was not exercised.
What changed from 2026?
From 1 January 2026 part two of article 267 of the Tax Code applies as amended by ZRU-1108: VAT on an invoice assigned to the high-risk category is not credited by the buyer, except where the tax is paid under the procedure of article 266-1. The risk category is visible before signing, so it has to be checked when the document is accepted, not at the return stage.
What happens if the supplier's VAT certificate is cancelled?
The tax is not creditable at its buyers either. When the certificate is reinstated, the credit is restored for the taxpayer and for its buyers as from the date of suspension. The practical conclusion: the status of the certificate is checked for every delivery, not once when the contract is signed.
What can be checked in Uzbekistan free of charge?
Registration data of a legal entity is issued by taxpayer number free of charge and automatically through a public service — the data providers are the Ministry of Justice and the Tax Committee. In addition, the register of unfair contractors on the public procurement portal is open, as are the lists of risky entities published by the Tax Committee.
What cannot be checked in Uzbekistan?
Open sources do not show a counterparty's real ability to perform: production facilities, staff, workload, financial standing over time. That is exactly what article 15 requires, and exactly what is covered by requesting documents, checking the facts on the ground and contractual protection, not by an extract.
Does the Russian approach to counterparty checks work here?
No. Uzbekistan has no equivalent of a full extract from Russia's unified state register, no Transparent Business service and no open case docket in the familiar form. The set of sources is different and narrower, so a checklist carried over from another jurisdiction creates a false sense of having checked.
What does a due diligence file look like?
It is a written report dated the day the transaction was concluded, recording for each criterion of article 15 what was checked, from which source and with what result, plus a conclusion on the risks. A screenshot with no date and no conclusion does not work as evidence.
What if there are risks but the deal has to go ahead?
Part of the risk is moved into the contract: a tax clause, representations as to facts, payment mechanics tied to performance, security. This does not replace the check, but it changes who bears the consequences if the counterparty turns out to be a problem.
Why you can trust us with this

Verifiable facts about us

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

  • Every rule is cited with a link to the current wording of the Tax Code on lex.uz rather than paraphrased.
  • We flag this separately: on lex.uz the Russian text of the 2026 amendments is marked as an unofficial translation — the official text of these rules is the Uzbek one, and in a disputed situation that is what you should check against.
  • We do not link to portal sections that return an empty page, and we do not pass Russian practice off as Uzbek — which is precisely what fills the internet in this niche.

This material is for general information and is not legal advice on your particular situation. Rules and tariffs change — check the current wording via the primary-source links above. To have your case assessed, send us a request.