Uzbekistan, Republic of
The taxable period for CIT is a calendar year.
CIT is reported quarterly before the 25th day of the month following the reporting quarter, with an annual return due by 25 March following the reporting year for enterprises with foreign investment and 15 February following the reporting year for other categories of CIT payers. PEs report on CIT once a year prior to 25 March following the reporting year.
Payment of tax
Uzbek enterprises, including enterprises with foreign investment, are required to make advance instalments of CIT in each quarter based on estimated profits in the quarter. The instalments are payable by the tenth day of each month. Final quarterly payments based on actual profit figures are payable no later than the filing deadline for the quarterly tax returns (which is the 25th day of the month following the period of assessment). In case the final quarterly payment is more than 10% higher than advance instalments made in this quarter, tax authorities have the right to recalculate the advance instalments based on the actual quarterly profit figures and charge late payment interest accordingly.
Final CIT payment should be made no later than the date set as the deadline for annual return submission.
Payment of CIT by a PE is made annually within a month after the filing deadline.
Tax audit process
New types of tax audits have been introduced to replace scheduled and non-scheduled tax audits, as follows:
- Audits conducted under consent of the authorised state body on coordination of inspections of an enterprise’s activities (i.e. audit of financial and economic activities of the taxpayer; audit conducted based on the application of individuals and legal entities claiming the taxpayer’s breach of the legislation or based on the outcomes of the risk analysis run by the tax authorities).
- Audits conducted upon notification of the authorised state body on coordination of inspections of an enterprise’s activities (i.e. audit conducted due to liquidation of a legal entity; audit to eliminate facts of production and sale of prohibited goods/services).
Statutory tax audits are to be carried out not more than one a year by district tax authorities, except for:
- Taxpayers compliant with the regulations: Not more than once in two years.
- Private banking and other private financial institutions: Not more than once in five years.
- Microfirms, small enterprises, and farms: Not more than once in three years.
Newly created microfirms, small enterprises, and farms are not subject to scheduled tax audit during three years from the date of their registration and two years for those producing excisable taxes and associated with the targeted use of budgetary and centralised funds and resources.
The tax audits are aimed at verification of the tax returns submitted by the taxpayer. Normally, the tax authorities will review the accounting records, copies of tax returns, statistics, and bank and other source documents.
Effective 1 January 2017, all types of unscheduled audits of business entities were abolished, except for audits due to liquidation of legal entity or short-term audits carried out exclusively by decision of the Republican Council on coordination of regulatory authorities. Also, all types of cross audits of business entities, including those under criminal investigation, were abolished.
The tax authority is required to notify the subject of a tax audit not less than 30 days before the tax audit start date.
In case of tax breaches revealed during tax audits, taxpayers should remove tax violations and pay respective taxes/obligatory payments and late payment interest within 30 days after the tax authority’s decision is released. If accomplished within the deadline, the tax authority’s decision on applying penalty may be cancelled. If not accomplished, the unpaid taxes/obligatory payments and late payment interest are to be withdrawn from (i) the taxpayer’s bank accounts (by issuing tax liability claim without acceptance), (ii) the taxpayer’s debtors (by issuing tax liability claim on the debts payable to taxpayer), or (iii) the taxpayer’s property (by issuing tax liability claim upon decision of the court).
Another form of monitoring accuracy and completeness of fulfilment of tax liabilities imposed by the tax authorities is ‘cameral control’, which is performed at the time of tax returns submission. The tax authorities may require the taxpayer to amend the tax return(s) if they have revealed mistakes or inconsistencies therein. The amended tax returns should be filed within ten days.
Furthermore, the concept of 'thematic express analysis’ is introduced. Thus, tax authorities may visit taxpayers to conduct thematic express analysis based on the results of ‘cameral control’ for verification of the information provided by taxpayers and eligibility to apply tax and customs incentives reflected in tax reports. Duration of the thematic express analysis should not exceed seven calendar days. During this analysis, taxpayers are allowed to voluntarily rectify the tax violations.
By virtue of the Presidential Decree #УП-5308 of 22 January 2018, a moratorium is declared for inspections of the economic activities of entrepreneurs by the regulatory authorities for two years. Inspections can be carried out only with respect to criminal cases and liquidation of legal entities.
Statute of limitations
The statute of limitations for tax purposes in Uzbekistan is set to five years.
Topics of focus for tax authorities
There are no officially announced areas of focus during tax audits. In practice, the tax authorities usually focus on currency control, cash discipline, deductibility of expenses for CIT purposes, and taxes on resources (e.g. excess profits tax, subsurface use tax).