Uzbekistan, Republic of
The Civil Code of the Republic of Uzbekistan provides that enterprises can establish and operate branches. However, the by-laws governing procedures for establishing entities with foreign investments do not provide sufficient guidance on establishing branches of foreign legal entities, creating a practical problem with registering of branches of foreign legal entities. Instead, such entities use a PE registration to perform business activities without establishing an Uzbek company.
Generally, taxation of PE’s income is similar to that of Uzbek legal entity, i.e. income of PE is subject to CIT at the rate of 15%. As of 1 January 2022, net profits after payment of CIT is considered as dividends and subject to taxation at a tax rate of 10%.
Net profits shall be a difference between gross income and expenses related to activities of a PE. Tax on net profits shall be paid along with CIT (not later than CIT report filing date).