Uzbekistan, Republic of

Corporate - Withholding taxes

Last reviewed - 23 July 2021

WHT is to be withheld and remitted to the state budget by entities paying income to non-residents if these entities qualify under a tax agent definition (i.e. by [i] Uzbek legal entities and [ii] non-residents operating in Uzbekistan via PE).

Income of non-residents subject to WHT (including income in the form of dividends, interest, and royalties) is to be paid without withholding of WHT at source or with application of a reduced WHT rate as provided by the tax treaty (with certain exemptions), provided that there is a duly formalised tax certificate issued by a competent authority confirming that non-residents are registered for tax purposes in the state with which Uzbekistan has the effective tax treaty.

The domestic WHT rates are as follows:

Payment WHT (%)
Dividends and interest to residents 5
Dividends and interest to non-residents 10
Insurance and reinsurance payments 10
Freight 6
Royalties, services (including management, consulting services), rents, other income 20

Double taxation treaty (DTT) relief

Foreign legal entities that do not carry on activities in Uzbekistan through a PE are subject to WHT on income from sources in Uzbekistan, subject to the terms of a relevant DTT. Uzbekistan has enforced DTTs with 54 countries.

DTTs in force establish WHT rates as follows:

Recipient WHT (%)
Dividends Interest Royalties
Austria 5(2b)/15 0(7c,7e,7f)/10 5
Azerbaijan 10 10 10
Bahrain 8 8 8
Belarus 15 10 15
Belgium 5(2a)/15 0(7c,7e,7f)/10 5
Bulgaria 10 0(7e)/10 10
Canada 5(1a)/15 0(7b,7e)/10 5(3,4,6)/10
China 10 0(7e)/10 10
Czech Republic 5(8c)/10 0(7b,7c,7e,7d)/5 10
Egypt 0 (7e)/5(8e)/10 0(7e)/10 12
Estonia 5 (8f)/10 5 10
Finland 5 (2b)/15 0(7b,7c,7e)/5 0 (6)/5 (5)/10 (4)
France 5(1a)/10 0 (7b,7c,7e,7d)/5 0
Georgia 5(8b)/15 0(7e)/10 10
Germany 5(8c)/15 0(7e)/5 3 (3,5,14)/5 (4)
Greece 8 0(7e)/10 8
Hungary 10 0(7e)/10 10
India 10 0(7b,7e)/10 10
Indonesia 10 10 10
Iran 8 10 5
Ireland 5 (2a)/10 5 5
Israel 10 10 5(4)/10
Italy 10 0(7a,7b,7e)/5 5
Japan 5(8g)/10 0(7b,7e)/5 0(4)/5
Jordan 7(8c)/10 10 20
Kazakhstan 10 0 (7e)/10 10
Kuwait 0(7e)/5(8c)/10 0(7e)/8 20
Kyrgyzstan 5 5 15
Latvia 10 0(7b,7e)/10 10
Lithuania 10 0(7b,7e)/10 10
Luxembourg 5(8f)/15 0(7d)/10 5
Malaysia 10 0(7e)/10 10
Moldova 5(1a)/15 0(7e)/10 15
(The) Netherlands 0(12)/5 (8f)/15 0(13)/10 0(13)/10
Oman 0(7e)/7 0(7e)/7 10
Pakistan 10 0(7e)/10 15
Poland 5(10a)/15 0(7e)/10 10
Romania 10 0 (7b,7e)/10 10
Russia 10 0(7c,7e)/10 0
Saudi Arabia 7 7 10
Singapore 5 5 8
Slovak Republic 10 10 10
Slovenia 8 8 10
South Korea 5(8c)/15 5 2(10)/5
Spain 5(8c)/10 0(7a,7b)/5 5
Switzerland 5(10b)/15 0(7b,7c,7d)/5 5
Tajikistan 5(8c)10 10 10
Thailand 10 0(7b,7e)/10(11)/15 15
Turkey 10 0(7e)/10 10
Turkmenistan 10 0(7e)/10 10
Ukraine 10 10 10
United Arab Emirates 0(7e)/5 (8c)/15 0(7e)/10 10
United Kingdom 5(1b)/10 5 5
Vietnam 15 0(7b,7e)/10 15

Notes

1a. Where the beneficial owner controls/holds directly or indirectly at least 10% of the voting power.

1b. Where the beneficial owner controls directly or indirectly at least 10% of the voting power (other than where the dividends are paid by an investment vehicle).

2a. Where the beneficial owner holds/controls directly at least 10% of the capital of the paying entity.

2b. Where the beneficial owner (other than a partnership) holds/controls directly at least 10% other capital of the paying entity. 

3.  Where royalties are paid for patents, trademarks, know-how, etc.

4.  Where royalties are paid for copyrights on literature, cinema, musical works, etc.

5.  Where royalties are paid for secret formulas, processes, or know-how.

6.  Where royalties are paid for computer software, patents, designs, models, or plans.

7.  Where one of the following conditions is met:

a. the payer of interest is the Government of that Contracting State or a local  authority thereof;

b. interest is paid in respect to debt claims or loans, guaranteed, insured, or aided by the state or on behalf of the state;

c. interest is paid in respect to credit sales of industrial, commercial, or scientific equipment, goods and merchandise, or provision of services by an enterprise to another enterprise; or

d. interest is paid in respect to a loan of any kind granted by a bank;

e. a recipient is the state, or local authority, the National Bank or any other similar financial institution wholly owned by the state;

  • in the case of U.A.E. it also includes Abu Dhabi Investment Authority, Abu Dhabi Fund for Economic Development or any other similar government institution that will be agreed by the competent authorities of the Contracting States
  • in the case of Finland it also includes the Finnish Fund for Industrial Co-operation Ltd (FINNFUND) or any other similar institution wholly or mainly owned by the State of Finland, as may be agreed from time to time between the competent authorities of the Contracting States
  • in the case of Germany it also includes Banking Institute for Reconstruction or German Financing Company for Investment in Developing Countries or another similar institution as well as loans secured by Hermes Credit Insurance Corp
  • in the case of Hungary it also includes the Eximbank Hungary Pte Ltd
  • in the case of Malaysia it also includes the Export-Import Bank of Malaysia Berhad (EXIM Bank) and the Bank Negara Malaysia
  • in the case of Oman it also includes the State General Reserve Fund, the Omani Investment Fund and any other statutory body or institution wholly or mainly owned by the Government of the Sultanate of Oman, as may be agreed between the competent authorities of the Contracting States
  • in the case of Thailand it also includes Export-Import Bank of Thailand
  • in the case of Turkey it also includes Turkish Eximbank.

f. interest paid in respect of a loan made, guaranteed or insured or a credit extended, guaranteed or insured by public entities the objective of which is to promote the export.

8a. Where the beneficial owner holds at least 25% of the capital of the paying entity.

8b. Where the beneficial owner (other than a partnership) holds at least 25% of the capital of the paying entity.

8c. Where the beneficial owner (other than a partnership) holds directly at least 25% of the capital of the paying entity.

8d. Where the beneficial owner holds at least 25% of the capital of the paying entity throughout a 365 day period.

8e. Where the beneficial owner (other than a partnership) holds directly at least 25% of the capital of the paying entity throughout a 365 day period.

8f.  Where the beneficial owner holds directly at least 25% of the capital of the paying entity.

8g. Where the beneficial owner holds directly at least 25% of the capital of the paying entity throughout a 365 day period.

9.   Where royalties are paid in respect to use or the right to use industrial, commercial, or scientific equipment.

10a. Where the beneficial owner holds no less than 20% of the capital of the paying company.

10b. Where the beneficial owner (other than a partnership) holds directly no less than 20% of the capital of the paying company. 

11.  Where the interest is received by any financial institution (including insurance companies).

12.  Under the provisions of the Netherlands’ Company Tax Act and the future amendments thereto, a company that is a resident of the Netherlands is not charged to Netherlands company tax with respect to dividends the company receives from a company that is a resident of Uzbekistan.

13.  If and as long as the Netherlands, under its national legislation, levies no WHT on interest or royalties paid to a resident of Uzbekistan, the WHT rate for interest and royalty income paid at source in Uzbekistan shall be reduced to 0%.

14.  Where the beneficial owner directly holds at least 25% of the property of the company paying the dividends throughout a 365 day period that includes the day of the payment of the dividend.