Uzbekistan, Republic of

The following notable changes were introduced to Uzbek legislation:

• From 1 January 2023, the value-added tax (VAT) rate is reduced from 15% to 12%.

• Desktop tax audits for validation of VAT refund claims are reduced from 60 days to 30 days.
• A new procedure is introduced allowing taxpayers to recover input VAT related to goods/services purchased in the period when VAT certificate was suspended (previously, such VAT was non-recoverable).
• ‘Large taxpayers’ are eligible to utilise their recoverable VAT amount towards import VAT payable at importation of goods.
• As of 1 April 2023, the VAT incentive for geological services provided within the framework of annual state programs for development and reproduction of mineral resource base at the expense of the state budget was abolished.
• The requirement to have at least 15% of the gross income from export operations to apply 0% corporate income tax (CIT) on export income has been abolished.
• The Tax Code explicitly stipulates the applicability of dividend-related clauses of double tax treaties (DTTs) to the permanent establishment’s (PE’s) net profit tax charged on PE’s after-tax profits.
• Application of increased rates of property tax in respect of abandoned buildings and unutilised manufacturing facilities has been abolished.
• The VAT incentive for turnover on implementation of research and innovation works carried out at the expense of the state budget was cancelled.
• The deadline for filing of annual personal income tax (PIT) and Social Tax (ST) returns is amended to 15 February (previously, 25 March).
• Excise tax rates at importation of alcohol and tobacco products are reduced by 5%.
• Excise tax rates on petrochemicals, as well as produced alcohol and tobacco products, were increased by 10% as of 1 February 2023.
• As of 1 November 2022, income from export of goods (services) is subject to 0% CIT rate irrespective of the share of export revenue in the total revenue (previously, minimum share of export was 15%).
• As of 1 January 2022, the net profit of non-residents operating in Uzbekistan via PE is equated to dividends and is subject to taxation at 10% (similar to dividends).
• Payers of turnover tax who switched to payment of CIT for the first time after 1 September 2022 are eligible to apply 50% reduced CIT rate during the following tax year, provided that their turnover does not exceed 10 billion Uzbekistani soum (UZS) during that tax year.
• CIT payers whose turnover after 1 September 2022 exceeded UZS 10 billion for the current tax year for the first time are eligible for 50% reduced CIT rate during the current tax year and following year, provided that during these tax periods their turnover does not exceed UZS 100 billion.
• Deadline for submission of a notification on advance payment is set as 15th day (previously 10th day) of the first month following the previous quarter.
• New deadlines for tax reporting and payments of property tax are introduced.
• Tax rate of subsurface use tax for mining of iron is reduced from 5% to 2%.
• A unified tax rate of 4% is introduced for all categories of turnover taxpayers.
• Payers of turnover tax may choose to pay fixed tax in lieu of turnover tax regarding their annual turnover.
• Deadline for filing tax reports and certificate of land tax on available non-agricultural land plots are set not later than 20 January of the current reporting year (previously 10 January).
• Deadline for tax payment (only for turnover taxpayers) also set not later than 20th day (previously, 10th day) of the third month of each quarter.
• Starting 1 April 2023, customs duty incentives on property imported by entities with foreign investments for use in their own production were abolished, unless otherwise provided by investment agreements signed before 1 January 2023.
• VAT and CIT payers with annual turnover of up to UZS 10 billion are now eligible to settle their tax liability in instalments during six months via notification mechanism (previously instalments option was available only upon clearance of respective application by the tax authorities).