Uzbekistan, Republic of

For Uzbek tax purposes, corporations are classified as resident or non-resident. The new edition of the Tax Code introduced amendments into the definition of tax residency.

A resident corporation includes the following legal entities:

• Uzbek legal entities (i.e. passed state registration in Uzbekistan).
• Foreign legal entities recognised as Uzbekistan tax resident under international agreements.
• Foreign legal entities with effective place of management in Uzbekistan.

Other legal entities are regarded as non-resident corporations for tax purposes.

Permanent establishment (PE)

PE is defined by the Tax Code as a “fixed place, through which the foreign legal entity carries out, in full or partially, entrepreneurial activity in the Republic of Uzbekistan”. The Tax Code further provides that a PE is also existent where (i) building site, installation or assembly object, or related activities exist/last for more than 183 days in any consecutive 12-month period, or (ii) service, including consulting services, is provided by a non-resident if they last (for one or more related projects or related entities) for not less than 183 days in any consecutive 12-month period.