Doing business in Uzbekistan - An introductory guide to tax and legal issues - EY
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Doing business in Uzbekistan An introductory guide to tax and legal issues
3 Doing business in Uzbekistan
Contents
Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1. Welcome to Uzbekistan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Highlights. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2. Getting started. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1. Arriving in Uzbekistan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.2. Forms of legal presence available in Uzbekistan . . . . . . . . . . . . . . . . . . 8
2.3. Establishing a legal presence. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3. Overview of tax rules in Uzbekistan. . . . . . . . . . . . . . . . . . . . . . . . 12
3.1. Implementation of the new Tax Code of Uzbekistan . . . . . . . . . . . . . . 13
3.2. Personal income tax and social tax . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
3.3. Corporate income tax (CIT). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3.4. Withholding tax (WHT) (other than personal income tax) . . . . . . . . . 17
3.5. Value added tax . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3.6. Other taxes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
3.7. Revenue tax . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
3.8. Tax administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
4. Overview of other laws that affect business administration . . . . . 22
4.1. Employment regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
4.2. Work permits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
4.3. Banking regulations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
4.4. Currency regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
5. EY in Uzbekistan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
Supporting our clients in a dynamic landscape . . . . . . . . . . . . . . . . . . . . . 27
Our major services. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Contact information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
6. Appendix. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
A.1. Double tax treaties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
A.2. List of countries with preferential tax regimes . . . . . . . . . . . . . . . . . . 31
Doing business in Uzbekistan 1
Preface 2 Doing business in Uzbekistan
This booklet is intended to provide
useful practical guidance on legal and
tax issues faced by foreign investors
when starting a business in Uzbekistan.
We hope that it will help investors
to avoid common pitfalls, and we
have highlighted areas where some
forethought and planning prevent
problems from arising. Uzbekistan
offers a wealth of opportunities and
places great importance on encouraging
foreign investment in key sectors of the
economy.
This guide has four sections:
1. Welcome to Uzbekistan
2. Getting started
3. Overview of tax rules in Uzbekistan
4. Overview of other laws that affect
business administration
This guide is a brief summary of the
rules in force as of 1 January 2021.
It is not a substitute for comprehensive
professional advice, which should
be sought before engaging in any
significant transaction or investment.
It should also be noted that this guide
does not cover all taxes in Uzbekistan.
We have focused here on the most
common and important types of taxes.
It is therefore essential to seek separate
advice as to the actual taxes applicable
to any particular business.
We wish you every success in this
exciting and dynamic environment.
Doing business in Uzbekistan 3
1 Welcome to
Uzbekistan
4 Doing business in Uzbekistan
Highlights
Time Business hours
Uzbekistan’s time zone is five hours ahead of Greenwich Uzbek offices are generally open from 9:00 am to 6:00 pm,
Mean Time (GMT). Monday to Friday, and are closed Saturdays and Sundays.
The table below shows time differences between Tashkent Uzbekistan fact sheet
and selected cities in the CIS and the world. Capital Tashkent
Hours ahead of or behind Administration Uzbekistan consists of 14 administrative units:
City the Republic of Karakalpakstan, 12 provinces
Tashkent (in winter)
(viloyats) and the city of Tashkent
Tokyo, Seoul +4
Bordering countries Kazakhstan, Kyrgyzstan, Tajikistan,
Beijing, Hong Kong +3 Turkmenistan, Afghanistan
Nur-Sultan, Almaty, Bishkek +1 Land area 448,900 km2
Tashkent 0 Population 34 million
Baku, Tbilisi, Yerevan -1 Language Uzbek
Moscow, Minsk, Istanbul -2 Central Bank Central Bank of the Republic of Uzbekistan
Kiev -3 Major cities Tashkent, Samarkand, Bukhara, Khiva
Paris, Frankfurt -4 Currency unit Uzbekistan Soum (UZS)
London -5 Exchange rate as of USD 1 = UZS 10 476.92
New York -10 1 January 2021 EUR 1 = UZS 12 786.03
RUB 1 = UZS 141.27
CNY 1 = UZS 1 601.78
Public holidays
Sources: Official sites of the President of the Republic of Uzbekistan,
The table below lists Uzbekistan’s official public holidays.
the Central Bank of Uzbekistan and the State Statistics Committee of
the Republic of Uzbekistan.
Holiday Date
New Year Holiday 1 January
International Women’s Day 8 March
Navruz holiday 21 March
Day of Memory and Honour 9 May
Ramadan Eid First day, e.g. 12 April*
Kurban Eid First day, e.g. 15 May*
Independence day 1 September
Teachers’ day 1 October
Constitution Day 8 December
* The dates of religious holidays in 2021 are indicated tentatively.
The dates vary from year to year based on the lunar calendar.
Doing business in Uzbekistan 5
2 Getting started 6 Doing business in Uzbekistan
2.1. Arriving in Uzbekistan Malaysia, Malta, Mexico, Monaco, • Nationals of certain countries who
Mongolia, Montenegro, Netherlands, hold diplomatic passports and have
New Zealand, Nicaragua, Norway, appropriate accreditation
Should you require assistance in Panama, Poland, Portugal, Saint
planning and managing your human • Holders of a red UN Laissez-Passer, a
Kitts and Nevis, Saint Lucia, Saint
capital needs, EY can advise on and diplomatic travel document issued by
Vincent and Grenadines, San Marino,
assist with obtaining work permits for the UN, are exempt from obtaining a
Romania, Serbia, Singapore, Slovakia,
foreign employees, tax registration, visa for a stay up to 30 days. Holders
Slovenia, South Korea, Spain, Sweden,
and tax and legal compliance for of a blue UN passport are subject
Switzerland, Trinidad and Tobago,
expatriate individuals. to simplified visa procedures: a visa
Turkey, UAE, Vatican, United Kingdom
will be issued within 2 days by the
• Members of flight crews of foreign Ministry of Foreign Affairs upon
Temporary visas airlines operating regular flights to presentation of an invitation letter by
In general, all foreign nationals and Uzbekistan (for the length of time the host party.
stateless persons are required to obtain between their flights into and out of
a visa to enter Uzbekistan. However, Uzbekistan) Since visa requirements are subject
the following individuals are not subject to frequent changes, individuals
• Nationals of the People’s Republic of
to general visa requirements and may should check the specific applicable
China and Hong Kong (for stays of up
enter Uzbekistan without a visa: requirements before planning a trip to
to 7 days)
• N
► ationals of the following CIS Uzbekistan.
countries: Azerbaijan, Armenia,
Belarus, Georgia, Kazakhstan,
Moldova, Russia, Ukraine, and
Kyrgyzstan (for stays of up to
60 days) and Tajikistan (for stays
of up to 30 days)
• N
► ationals of the following countries
for stays up to 30 days: Andorra,
Antigua and Barbuda, Argentina,
Australia, Austria, Bahamas,
Barbados, Belize, Belgium, Bosnia and
Herzegovina, Brazil, Brunei, Bulgaria,
Canada, Costa Rica, Chile, Croatia,
Cuba, Cyprus, Czech Republic,
Denmark, Dominica, Dominican
Republic, El Salvador, Estonia,
Finland, France, Germany, Greece,
Grenada, Guatemala, Honduras,
Hungary, Iceland, Indonesia, Ireland,
Israel, Italy, Jamaica, Japan, Latvia,
Lithuania, Liechtenstein, Luxemburg,
Doing business in Uzbekistan 7
Business visas. Business visas are company, submitted to the Consular companies, representative offices,
issued to foreign individuals arriving in Department of Uzbekistan. permanent establishments of foreign
Uzbekistan for business purposes (e.g. entities, etc.
Unless exempt from visas as mentioned
for a business trip or negotiations, to
above, citizens of the following countries
sign contracts or to attend conferences, Should you require more information on
are eligible to obtain an entry visa to
symposiums, forums, exhibitions, the nature and uses of various business
Uzbekistan through the «EVISA.MFA.UZ»
concerts or cultural, scientific, sporting forms in Uzbekistan, EY offers tax and
system or obtain tourist visas under
or other events). legal advice on how to structure
simplified procedures at Uzbek consular
offices: Albania, Algeria, Angola, a business in Uzbekistan depending
Investment visa. An investment visa may
Bahrain, Bangladesh, Bolivia, Cambodia, on the investor’s specific area of
be issued to shareholders/participants
Cameroon, Cape Verde, China (including business or commercial plans, as well
or founders of enterprises with foreign
Hong Kong), Colombia, Cote d’Ivoire, as a full range of company formation
investments and to members of their
Ecuador, Egypt, Fiji, Gabon, Ghana, and registration services.
families for a period of three years, at
the end of which it may be extended. Guyana, India, Iran, Jordan, Kiribati,
Kuwait, Laos, Lebanon, Maldives, In this section we give details of the
In addition, foreigners who have invested Marshall Islands, Mauritius, Micronesia, four types of business entities most
at least USD 3 million in production or Morocco, Nauru, Nepal, Oman, Palau, commonly used by foreign investors.
service industries in Uzbekistan and Paraguay, Peru, Philippines, Republic
shareholders/participants or founders of Korea, Qatar, Samoa, Saudi Arabia,
of enterprises with foreign investments Senegal, Seychelles, Solomon islands,
may apply for a 10-year residence South Africa, Sri Lanka, Suriname, 2.2.1. Joint stock companies (JSCs)
permit under a simplified procedure. Thailand, Tonga, Tunisia, Uruguay, A JSC is a legal entity that is separate
A foreigner with a residence permit Vanuatu, Venezuela and Vietnam. and distinct from its shareholders. As a
does not need to obtain visas and work general rule, a JSC’s shareholders are
permits to live and work in Uzbekistan. The electronic visa is valid for 30 days
not liable for the JSC’s liabilities. A JSC
from the date of issue. The processing
Work visas. Work visas are issued to may have one or more shareholders.
time for electronic visa applications is
foreign individuals arriving in Uzbekistan 2 (two) working days, excluding the Generally, there is no minimum charter
for employment. A work permit (if appli- day the application is submitted. The capital requirement for a JSC. However,
cable) and a work confirmation must electronic visa is sent to the e-mail regulations governing certain activities
be submitted to Uzbek foreign affairs address of the foreign citizen as normally subject to licensing (e.g.
authorities in order to obtain a work indicated in the application submitted banking and insurance activities) set out
visa (subject to planned changes). via the «EVISA.MFA.UZ» web portal. minimum capital requirements for JSCs.
See the ”Work permits” section below
for details. Since establishing a JSC is a very
2.2. Forms of legal presence time-consuming and highly regulated
Issuance of visas. Visas are issued process, investors usually prefer to opt
abroad by Uzbekistan consulates (the available in Uzbekistan for an LLC when deciding on their form
Consular Department of the Embassy There are a number of legal forms of presence in Uzbekistan. However,
of Uzbekistan). Generally, business available for foreign and local investors for certain types of businesses (such
visas are issued based on a letter of wishing to establish a presence in as banks) the JSC is the only available
invitation from a local Uzbek company, Uzbekistan, including but not limited to vehicle for establishing a presence in
or a representative office of a foreign joint stock companies, limited liability Uzbekistan.
8 Doing business in Uzbekistan2.2.2. Limited liability companies
(LLCs)
Like a JSC, an LLC is a legal entity in
which the participants are not liable for
the company’s liabilities and bear the risk
of losses from the company’s activities
only to the extent of their contributions
to the charter capital. An LLC may
have one or more participants. An LLC
may not be established by one entity
that in turn has only one shareholder/
participant, unless the former entity is a
JSC.
The main difference between these two
types of entities is that an LLC does not
issue shares. Instead, participants have
ownership (participating) interests in
the company. In addition, LLC may, as an
alternative fund-raising option (besides
equity-based financing), issue bonds
subject to similar requirements as those
set for bonds issued by JSCs.
As a general rule, as in the case of a JSC,
there is no minimum capital requirement
for an LLC. However, regulations
governing certain activities normally
subject to licensing (e.g. insurance
activities) may require LLCs to comply
with the minimum capital requirements
for those specific types of business.
2.2.3. Representative offices (RO)
An RO is a structural subdivision of
a legal entity that is established at
a different location from that of the
legal entity. Since an RO is not itself
a legal entity, rights and obligations
are assumed by the legal entity that
established the RO (the main legal
entity). It is explicitly stated in the law
Doing business in Uzbekistan 9that an RO cannot conduct business We are aware of a draft law that would 2.3.1. State registration
activities. An RO is established enable the registration of branches State registration in Uzbekistan is
exclusively to represent and protect the foreign companies’ in Uzbekistan in carried out based on a «one-stop-
interests of the main legal entity, and its the future, but it is not clear when this shop» principle whereby all registration
activities must be limited to marketing law will be passed and enter into force. documents must be submitted to unified
and non-transactional support for the Alternatively, it is possible to register centres for the provision of public
head office. If any commercial activities a permanent establishment («PE») of services to business entities («One-
conducted through an RO, the RO’s a foreign legal entity for tax purposes Stop-Shop Centre»). Upon submitting
accreditation may be cancelled by the in Uzbekistan. This is done purely for a complete set of documents, provided
state authorities. tax registration purposes for a specific that the authorities do not raise any
project, and a PE does not constitute issues, the LLC will be registered with
2.2.4. Branches/PEs a legal form. justice, tax and statistics authorities —
Uzbek law does not explicitly restrict/ all at the same time.
prohibit the establishment of branches in 2.3. Establishing a legal There is an option to submit
Uzbekistan by foreign entities. However, documents to the One-Stop-Shop
the registration and activities of
presence
Centre electronically through the
branches of foreign companies are not As a rule, all legal entities and «e-government» web portal. This
regulated at all. In practice, therefore, representative offices in Uzbekistan requires the use of an electronic digital
the Uzbek authorities do not register must be registered or accredited with key, which means that, in practice, legal
branches of foreign legal entities. the appropriate government authorities. entities established by foreign entities
10 Doing business in Uzbekistancannot yet be registered through the An RO is considered to be accredited tax authority to which tax and other
e-government portal, since foreign from the date of issuance of a certificate payments must be made.
legal entities founding an Uzbek entity of accreditation by the Accreditation
Under Uzbek law, government
are not currently allowed to obtain Authority. Generally, accreditation is
authorities (including tax authorities)
an electronic digital key. granted to an RO for a term of 1 to 3
require legal entities and ROs to be
years, which may be extended upon
Uzbek law requires a standard set of present at the legal addresses indicated
the company’s request. In practice, the
documents, i.e. statutory documents in their foundation documents and in the
Registration Authority issues certificates
prepared in the Uzbek language, to be registration records of the authorities.
of accreditation with a limited term
submitted in order to complete the state
not exceeding 1 year, subject to If an entity is not actually present at its
registration of a legal entity.
annual extension. As a rule, the legal address, i.e. the tax authorities
Documents submitted to the One-Stop- extension of accreditation is a relatively cannot find anyone representing the
Shop Centre must be accompanied by straightforward process. entity at the time of their visit, the entity
a bank document confirming payment of may be subject to an administrative fine,
the state registration fee (the amount of and its corporate bank accounts may be
which depends on the type of the entity 2.3.3. Location (legal address) seized.
to be registered). The documents must A legal entity’s location is the address
also be duly signed, sealed, notarized indicated in its foundation documents
and, where appropriate, legalized (the charter and, if there is more 2.3.4. Opening a bank account —
or apostilled. Otherwise, the Uzbek than one participant/shareholder, the for companies and individuals
authorities may reject the documents, foundation agreement). Bank accounts may be opened with a
which would delay the registration
Under Uzbek law, the location of a local bank in Uzbekistan in the national
process considerably. Under Uzbek
legal entity is the place where its and foreign currency.
law, the registration of a legal entity
should take no more than 30 (thirty) state registration takes place. The Uzbek legal entities (residents) may
minutes. In practice, it should not take foundation documents may establish open and use foreign currency accounts
much longer than this provided that the that the location of a legal entity is the with foreign banks outside Uzbekistan
documents are complete, duly signed place where its permanently operating subject to decisions of the President
and meet the statutory requirements. governing body (i.e. its director or board or the Government of Uzbekistan or
of directors) is situated or the place international agreements allowing the
where its main business is conducted. opening and use of accounts in national
2.3.2. Accreditation of representative However, a private household may not or foreign currency with banks abroad.
offices be indicated as the legal address of a Foreign legal entities (non-residents)
legal entity. carrying on activities in Uzbekistan
There is a separate procedure for
The location affects a legal entity’s through representative offices and PEs
establishing representative offices
registration and other legal matters, may open and use bank accounts in
of foreign entities in Uzbekistan.
such as the determination of the court Uzbekistan in both national and foreign
Representative offices of foreign legal
with which a statement of claim should currencies.
entities are subject to accreditation with
the Ministry of Investments and Foreign be filed in litigation (statements of
Trade of the Republic of Uzbekistan (the claim are usually filed with a court
“Accreditation Authority”). at the defendant’s location) or the
Doing business in Uzbekistan 113 Overview of tax rules in Uzbekistan 12 Doing business in Uzbekistan
In the sections that follow we describe the most important taxes in force in Uzbekistan. There are a number of
other less significant or industry-specific taxes such as excise tax and a number of taxes on “subsurface users”,
i.e. oil, gas and mining companies. It is important to conduct a thorough review of any proposed business
activity to determine the actual taxes that apply to it.
3.1. Implementation 3.2. Personal income A resident is generally defined as:
of the new Tax Code of tax and social tax (i) a
n individual who is physically
Uzbekistan present in Uzbekistan for over
EY offers advice and support with 183 days in any period of up to
The new Uzbek Tax Code, which came all aspects of tax compliance for 12 months beginning or ending
into effect from 1 January 2020, individuals and employers as well as in a calendar year for which tax
introduced substantial changes and a payroll processing. EY also provides tax residency is determined
number of new concepts compared with and legal assistance to high-net-worth
the previous version of the Code. (ii) an individual who is physically
individuals.
present in Uzbekistan for less than
Among the main changes are: (i) the
183 days, but more than in any
introduction of transfer pricing rules,
Taxpayers and residency other state in a calendar year
the controlled foreign company concept
and a tax consolidation regime for CIT Both residents and non-residents of
Accordingly, non-residents are generally
purposes; (ii) the introduction of thin Uzbekistan are subject to personal
those individuals who do not meet the
capitalization rules; (iii) the introduction income tax. Residents are taxed on their
above-mentioned tests.
of a general anti-abuse (substance-over- worldwide income, while non-residents
form) rule; and (iv) the extension of the are taxed only on their Uzbek source
definition of tax residency to include income.
foreign companies that have their place
of management in Uzbekistan.
However, it is stipulated that the transfer
pricing, controlled foreign company
and tax consolidation provisions (items
under (i) above) will take effect from
1 January 2022.
Doing business in Uzbekistan 13Taxable income Tax compliance at the time income is paid, but not later
Income of individuals consists of The tax year in Uzbekistan is the calendar than the deadline for the submission of
employment income, property income, year. A withholding obligation is placed monthly reports.
in-kind income and other types of on Uzbek legal entities, individual A foreign citizen who becomes a tax
income. In general, all types of income, entrepreneurs (where applicable), foreign resident of Uzbekistan is obliged to
including benefits in kind, are taxable in legal entities operating in Uzbekistan file an annual tax return not later than
Uzbekistan unless they are specifically through permanent establishments or 1 April following the reporting year
exempt. Income that is specifically representative offices, etc. (‘tax agents’) on his/her worldwide income. The tax
exempt from tax includes alimony, state which make salary-related payments assessed in the annual tax return (i.e.
pension income, etc. to individuals and provide benefits to any outstanding liability) must be paid
employees. Tax agents are responsible by the individual not later than 1 June
Rates for the proper assessment, withholding following the reporting year. If foreign
General personal income tax is levied at and remittance of personal income individuals who are tax residents
a flat rate of 12% for residents, while for tax. Tax agents are also obliged to file permanently leave Uzbekistan, they
non-residents a flat rate of 20% applies. monthly reports on income paid to their are also obliged to file a ‘departure’ tax
employees and tax withheld thereon return not later than one month before
Dividends and interest payable to tax-
by the 15th of the month following departure and the resulting tax liability
resident individuals are subject to tax at
the reporting month and must submit must be paid within fifteen days of filing
the rate of 5%, while for non-residents
an annual return together with their the ‘departure’ tax return.
the tax rate for dividends and interest is
annual financial statements1. Personal
10%. Individual entrepreneurs with annual
income tax must be paid to the budget
revenue below UZS 100 million (approx.
USD 9,545) must also pay personal
income tax on the basis of an annual
return or pay a fixed tax. The amounts
of the fixed tax vary based on the type
and location of activity.
Mandatory payments to social funds
Social tax
Employers are required to assess and
pay social tax at the current rate of
12% (25% in the case of state-funded
organizations) of gross payroll (i.e. at
the employer’s expense). The assessed
amount of social tax must be paid to
the budget on a monthly basis (not
1
ot later than 15 February following the reporting year (or not later than 25 March following the reporting year for companies with foreign investments and
N
non¬residents operating through a PE).
14 Doing business in Uzbekistanlater than the monthly tax return filing 3.3. Corporate income (especially documents used to support
deadline). Similarly, a cumulative return deductions) are particularly high in
must be submitted to the tax authorities tax (CIT) Uzbekistan.
on a monthly basis not later than
the 15th of the month following the EY offers the following services
reporting month, and an annual return in the area of corporate income tax: Depreciation for tax purposes
must be submitted together with the • Advisory and structuring To qualify as a fixed asset for tax
annual financial statements. • Assistance with tax compliance purposes, an asset must be defined as
of legal entities at every step of such under accounting legislation.
Employee pension fund contributions
the process For tax purposes, assets may be
Employers must make monthly mandatory • Tax review and due diligence services depreciated up to the maximum rates
contributions to individual funded • Other tax-related services shown in the table below:
pension accounts of local employees
(foreign citizens without Uzbekistan Type of fixed asset Maximum
residence permits are generally not Payers depreciation
rate
subject to such contributions) at the Taxpayers for CIT purposes are (i)
rate of 0.1% of their gross employment Uzbek resident legal entities on income Buildings, structures 3%
income. These contributions are from worldwide sources, (ii) foreign Trains, ships, aeroplanes 4%
deductible from amounts of personal legal entities that carry on activities
Pipelines, communications
income tax payable by tax agents. in Uzbekistan through a permanent equipment, power lines and 8%
establishment (PE), (iii) individual equipment
entrepreneurs with an annual revenue
Production machinery and
Other individual taxes over UZS 1 billion (approximately USD 15%
equipment
95,448) or who become CIT payers on
Property tax Cars, computers and office
a voluntary basis, etc. equipment
20%
The property tax is imposed on
buildings and apartments possessed by Uzbek legal entities with an annual All other assets 15%
individuals. The rates vary from 0.23% turnover less than UZS 1 billion
to 2% applied to the cadastral value of (approximately USD 95,448) are eligible Land, construction-in-progress, and
the property. for simplified taxation (revenue tax) certain other assets are not depreciated.
instead of CIT and output VAT (see the
Intangible assets are amortized for tax
Land tax “Revenue tax” section).
purposes over the useful life of the asset
An individual granted permanent or five years (if the useful life cannot be
possession of a land plot is subject to determined).
land tax at a fixed rate depending on Taxable income
the location of the land. For example, in Taxable income of Uzbek legal entities
the city of Tashkent, the rates vary from is determined as aggregate income Investment deduction
UZS 471.8 (approximately USD 0.045) less qualifying tax-deductible expenses, Taxpayers are allowed to make an
to UZS 1,193.6 (approximately USD with account taken of tax reliefs (where investment deduction amounting to:
0.114) per square meter per annum, applicable) and deductions provided for
depending on the location of the land in the Tax Code and other legal acts. The • 10% of the cost of new production
plot. required standards of documentation equipment, expenditure on the
Doing business in Uzbekistan 15modernization and retrofitting of interest expenses above the calculated agricultural goods, exporters (insofar
production facilities, etc. thresholds must be treated as non- as profit from exports is concerned), et
deductible for CIT purposes. al. are subject to CIT at 0% (if certain
• 5% of expenditure on the expansion
conditions are met).
of production through the new Tax rate and compliance
construction or reconstruction of The regular CIT rate is 15%. This rate The tax period is a calendar year.
buildings and structures used for also applies to Uzbek enterprises with Quarterly CIT returns must be filed
production purposes foreign participation and PEs of foreign not later than the 20th of the month
companies. For commercial banks, following the reporting quarter and an
Thin capitalization annual return must be filed not later
mobile telecommunications, operators,
The new Tax Code introduced thin than the 1 March of the following year.
legal entities that manufacture cement
capitalization rules effective from
(clinker) or polyethylene granules, and The final tax liability must be paid by
1 January 2020. If the controlled
markets and shopping malls, the CIT the deadline for filing tax returns.
liability of a taxpayer (i.e. loans provided
rate is 20%. For taxpayers included in Companies with revenue of more than
by entities classed as related parties)
the National Register of E-commerce UZS 5 billion (approximately USD
is more than three times greater than
Entities that sell goods and services 477,240) in the preceding calendar
the taxpayer’s internal capital (more
online, the CIT rate is 7.5%. Meanwhile, year must pay monthly advance
than 13 times in the case of banks
taxpayers that carry on activities in payments not later than the 23rd of
and leasing organizations), the thin
the social sphere, certain producers of each month of the reporting period.
capitalization rules must be applied and
16 Doing business in Uzbekistan3.4. Withholding tax (WHT) • Lease payments • A WHT return must be filed not later
than the 20th of the month following
(other than personal • Insurance premiums
the calendar month in which income
• Telecommunications and freight
income tax) charges
was paid to the non-resident
Uzbek source income of a non-resident • Fees for services, etc. Dividends payable to Uzbek tax residents
legal entity (without a PE) doing are subject to domestic WHT at the rate
business in or with Uzbekistan is subject of 5%. Starting from 1 January 2020,
to WHT at the source of payment. Tax rates and compliance interest payable to Uzbek tax resident
companies is not subject to domestic
Type of income Rate WHT (with certain exceptions); instead,
Tax agents of non-residents of WHT it is included in the aggregate income
Any tax-registered entity that pays of the interest recipient and assessed
Interest, dividends 10%
Uzbek source income to a foreign to CIT.
company is potentially a tax agent with Insurance premiums under
the responsibility to withhold tax from insurance, co-insurance, and 10%
reinsurance agreements
the gross amount of the Uzbek source
income of the non-resident (without Income from international 3.5. Value added tax
transportation and 6%
deductions).
telecommunications services EY offers help with VAT risk
Other income 20% identification, VAT compliance support
Taxable income and cross-border VAT planning.
Taxable income includes, but is not
limited to: Interest on certain loans made by Payers and registration
financial institutions and certain types of
• Dividends and interest VAT payers are (i) Uzbek legal entities
income of banks are subject to 0% WHT.
on a general basis, (ii) individual
• Income from the sale of property
Most double tax treaties (DTT) entrepreneurs whose annual revenue
located in Uzbekistan: shares, stocks
concluded by Uzbekistan either provide exceeds UZS 1 billion (approximately
(except for stocks traded on a stock
for exemption from Uzbek WHT or USD 95,448) or who register as VAT
exchange), and real estate. Taxable
provide for the reduction of WHT payers on a voluntary basis, (iii) foreign
income is defined as the amount
rates to 0%-15%. However, specific legal entities that sell goods or services
by which the sale price exceeds the
requirements must be met for DTT in the territory of Uzbekistan if the place
original purchase price
provisions to be applied. Please refer to of supply is deemed to be Uzbekistan
• Income from the sale of goods in the Appendix hereto for the list of DTTs. (e.g. electronic services sold to
the territory of Uzbekistan via a individuals via the Internet), (iv) foreign
Withholding tax is withheld and remitted
commission agency agreement or legal entities operating in Uzbekistan
by tax agents. The general rules are:
other similar agreement. Taxable through a PE, and (v) legal entities
income is defined as the excess of the • Tax must be withheld and paid not and individuals that import goods into
amount paid to foreign entities over later than the date following the day Uzbekistan (import VAT), etc. VAT
the original purchase price the income was paid to the non- payers are assigned a VAT registration
resident number.
• Royalties
Doing business in Uzbekistan 17The standard rate of VAT is 15%.
VATable turnover
VAT is levied on turnover derived
from the supply of goods and services
in Uzbekistan (based on the place
of supply rules) and imports into
Uzbekistan, unless they are zero-rated
or specifically exempt. Any excise tax
paid is included in the taxable base for
VAT purposes.
VAT payable to the budget is generally
determined as output VAT less allowable
input VAT. Input VAT incurred in
connection with the supply of exempt
goods and services and non-business
costs cannot be offset against output VAT.
Purchase of services from
non-residents (reverse charge
VAT / withholding VAT)
Under the place of supply rules, services
are deemed to be supplied at the
location of the business activity of the
purchaser of the services, except for
certain specified services. Where such
services are rendered by a non-resident,
the Uzbek purchaser of the services
is considered as a tax agent for VAT
purposes, i.e. the Uzbek purchaser has
an obligation to assess VAT based on
the VAT-inclusive price of the services
and withhold and remit VAT to the
budget on behalf of the non-resident.
However, if the contract for the supply
of services does not take into account
Uzbek VAT, the purchaser of the
services is required to self-assess and
pay VAT to the budget on top of the
price of the services (in a similar way to
the reverse charge mechanism). That
VAT may be offset against output VAT in
18 Doing business in Uzbekistanthe normal manner. calculate Uzbek VAT based on turnover quarterly VAT returns (electronically)
from those services (if the place of and pay the calculated amount of VAT to
Zero rating
supply is deemed to be Uzbekistan), file the Uzbek tax authorities.
Export sales of goods, international
transportation services and utility services
provided to individuals are generally taxed 3.6. Other taxes
at a zero rate.
The table below summarizes other significant taxes.
Exempt supplies Nature of tax Rate
VAT-exempt supplies and imports Excise tax: imposed on a specific range of services and goods Various
include: produced in Uzbekistan or imported into Uzbekistan. Goods
subject to tax include oil and gas products, alcohol, tobacco,
• fi
► nancial services etc. Services subject to tax include mobile telecommunications
• i► nsurance services services.
• g
► oods and services purchased by Property tax: imposed on the annual average depreciated value 2%
legal entities using a loan provided by of immovable property and certain other assets. Land is exempt
international or foreign government
Subsurface use tax: imposed on the extraction of natural Sales 2.6% to 30%
financial institutions, provided that
resources. Tax is imposed on the sale price of extracted natural Waste 0.78% to 9%
such exemption is provided for in the
resources and components and on waste derived from the
legislation, etc. extraction or processing of natural resources
Signing and commercial discovery bonuses for subsurface users: Various
VAT compliance payable to the state budget through the tax authorities
The VAT tax period and reporting period
Motor vehicle levy: imposed on sales/purchases of cars and other Various
is a calendar month. VAT returns must
vehicles
be filed and VAT due must be paid
not later than the 20th of the month Water use tax: standard rates per cubic metre Surface water UZS 182
following the reporting month. (approximately USD 0.017)
VAT payers with a monthly revenue Underground water UZS 221
below UZS 1 billion (approx. USD (approximately USD 0.021)
95,448) are entitled to calculate and Land tax: imposed at a fixed rate per hectare; varies depending Various
pay VAT on a quarterly basis (instead of on the location, quality and purpose of the land plot
the standard monthly basis). Example: rate in Tashkent
Zone 1 is UZS 208.2 million
(approx. USD 19,872) per
VAT on electronic services supplied by hectare
non-residents to individuals
Starting from 1 January 2020, a
non-resident company that supplies
electronic services to individuals living in
Uzbekistan via the Internet (B2C) must
register as a VAT payer in Uzbekistan,
Doing business in Uzbekistan 193.7. Revenue tax Revenue tax rates established for the 3.8. Tax administration
year 2021 vary depending on the type
Legal entities with an annual turnover of business and location, e.g. from 1-2% The tax administration rules in
(revenue) not exceeding UZS 1 billion (for wholesale/retail trading in very Uzbekistan are complex, and penalties
(approximately USD 95,448) may remote areas) up to 25% (pawnshops, for even minor infringements can be
choose to pay revenue tax (instead brokerage houses). The standard rate severe.
of CIT and output VAT). Individual is 4%. The reporting period for revenue
entrepreneurs whose annual revenue tax is a calendar quarter. The tax return EY offers comprehensive tax
is over UZS 100 million (approximately filing deadline is the 15th of the month compliance and tax due diligence
USD 9,545) but less than UZS 1 billion following the reporting period. The services to assess in-house tax
are also eligible to pay revenue tax. The annual tax return must be submitted not compliance risks, as well as on-site tax
tax base for revenue tax is generally later than 15 February of the following audit support and a full range of tax
gross revenue (with some adjustments). year. appeal services.
20 Doing business in UzbekistanTax accounting policy may sometimes even result in criminal Penalties and interest
Starting from 1 January 2020, proceedings. Interest is charged on late tax payments
taxpayers are required to have a Tax at one three-hundredths (1/300) of the
Accounting Policy, which they may draw Assessments refinancing rate set by the Central Bank
up in any form. of Uzbekistan (approximately 0.047%
Upon completion of a tax audit, the based on the refinancing rate effective
tax authorities usually issue a tax audit as at 1 January 2021) for each day of
Tax returns report. If no violations of tax law are the delay.
Tax reports (including returns and discovered, a note to that effect is made
calculations) must be compiled and in the tax audit report. Otherwise, based
submitted by the taxpayer to the on the findings of the report, the tax Penalties imposed on legal
local tax authority for their registered authorities issue a decision to impose entities for tax violations include
address. Legal entities and individual audit-based assessments of taxes the following:
entrepreneurs generally prepare and and other obligatory payments plus
• T
► he penalty for non-registration or
submit tax reports electronically. applicable penalties and interest.
late registration by a foreign legal
Appeals entity carrying on activities leading
Tax audits Taxpayers may, within set time limits, to a permanent establishment in
file appeals against decisions of tax Uzbekistan is 10% of income earned
Taxpayers are subject to tax audits, from the date on which the activities
and it is vital to manage the tax audit authorities in the following order:
began, but not less than
process. There are various types and 1. appeal to a higher tax authority UZS 10 million (approximately
categories of tax audit. USD 955)
2. appeal to a court (only after step
Tax audits can cover any period within 1 has been completed, unless the
the tax statute of limitations, which • The penalty for late registration as
decision being contested was issued
is generally 5 years. Tax audits can a VAT payer is 5% of revenue received
by the highest tax authority – the
be intrusive and time-consuming and from the registration date required
State Tax Committee)
by tax law to the date of actual
registration, but not less than
UZS 5 million (approximately
USD 477)
• The penalty for the understatement
of tax liability is 20% of the
additionally assessed tax liability
• The penalty for concealing revenue is
20% of the concealed revenue, etc.
In addition, administrative fines may be
imposed on company officers for tax
offences. In certain cases, they may also
face criminal proceedings.
Doing business in Uzbekistan 214 Overview of other laws that affect business administration 22 Doing business in Uzbekistan
4.1. Employment employment agreements, amendments 4.2. Work permits
thereto and termination of employment
regulations agreements. All employment As a general rule, a foreign citizen who
The Uzbek Labour Code and other agreements must be simultaneously comes to Uzbekistan to work (i.e. who
labour regulations apply to both local registered with the Unified National has been hired under an employment
and foreign citizens, including stateless Labour System. agreement) may work in the country
persons, working in Uzbekistan on only after obtaining confirmation of
At the time of writing, a new version the right to work in Uzbekistan (“work
the basis of employment agreements of the Labour Code is being drafted. It
with their employers. Furthermore, confirmation”) issued in his/her name
is expected that the new Code may be on the basis of the permit to hire foreign
employment relationships within enacted during 2021 and will include
organizations that are fully or partially labour (“work permit”) obtained by the
more extensive provisions on the rights employer.
owned by foreign legal entities or and obligations of employees and
individuals are also regulated by Uzbek employers, as well as provisions aimed This rule applies to all foreign employees
labour law. at protecting the interests of various except for those who are specifically
An employment agreement with an categories of employees, regulating the exempt, such as employees of ROs
employee must be concluded in writing. employment of foreign and stateless accredited by the Accreditation
The terms of an employment agreement persons, and establishing, personal data Authority (up to 5 (five) employees) or
are determined by mutual consent of protection and processing requirements. individuals hired within the framework of
the employee and employer and must intergovernmental treaties.
also comply with the requirements
established by the Labour Code and
other relevant labour regulations.
Employment agreements may be
concluded for a fixed or indefinite
term. An employment agreement may
establish a probation period, which
should not generally exceed 3 (three)
months.
The Unified National Labour System
was brought into use from 1 January
2020 with the aim of standardizing
and digitalizing employment relations.
It serves as an electronic database
of individuals’ employment histories,
effectively replacing the old system of
“labour books”. The Unified National
Labour System includes information
on work experience and registered
employment relationships, including
details (e.g. date, registered number) of
Doing business in Uzbekistan 23Although a work confirmation Centre, after which the documents are consecutively, and both documents are
may appear to be a personal work transmitted to the government body normally issued within 30 (thirty) days.
permit for a foreign citizen, it is the responsible for issuing work permits
A work permit is issued for a period of
responsibility of the employer to apply and work confirmations - the Agency
1 (one) year and may be extended.
for it. Neither a work permit nor a for External Labour Migration Matters
work confirmation may be transferred (the «Agency»). As a rule, the Agency In order to create favourable conditions
to other employers. Hence, a foreign has 15 (fifteen) days to review the for the attraction of qualified foreign
employee’s employment and his/her application and issue a work permit. specialists, increase the investment
work confirmation are attached to that appeal of the Republic of Uzbekistan and
specific employer. Furthermore, only The same timeframe applies to work stimulate the attraction of competitive
local employers may apply for work. confirmations. In practice, when an human resources, qualified and highly
employer applies for a work permit qualified foreign specialists (experts)
Documents required to obtain a work it should simultaneously apply for at may be granted work confirmations for
permit and work confirmation must least one work confirmation. In this up to 3 (three) years with an unlimited
be submitted to a One-Stop-Shop case, the two processes are carried out number of extensions.
24 Doing business in UzbekistanPlease note that starting from 2021 the The minimum charter capital for banks 4.4. Currency regulations
requirement to obtain a work permit is is set at UZS 100 billion (approximately
expected to be abolished. Instead, USD 9.5 million). Foreign banks, foreign Currency law allows cross-border
a maximum quota for the hiring of financial institutions and banking transactions to be carried out in
foreign personnel is expected to institutions with good investment any currency of the parties’ choice.
be introduced. At the same time, ratings can open subsidiary banks However, transactions within Uzbekistan
the requirement to obtain the work or participate in the capital of local must take place only in soums (UZS),
confirmation that authorizes a banks subject to certain requirements. the national currency of the Republic
foreign citizen to work in Uzbekistan Other non-financial foreign entities of Uzbekistan (subject to certain
is expected to continue to apply. face stricter requirements, such as a exceptions).
Updated regulations setting out the minimum rating requirement for the Currency operations may be subject to
new requirements have not yet been entity and its origin country and a 50% registration and subsequent monitoring,
published (at the time of writing). limit on their ownership interest in the depending on the substance of the
bank. transactions.
EY offers a range of legal, tax, payroll At present, Uzbekistan is working Generally, legal entities are allowed
and work permit services to help you on re-organizing and privatizing at to purchase foreign currency from
structure your operations in Uzbekistan least 6 local banks, including with the commercial banks in order to fulfill their
efficiently from a human resources involvement of foreign investors. The obligations under the following types of
perspective and ensure compliance main goal of privatization is to reduce international transactions: imports of
with tax, payroll and labour regulations. the state’s share in the banking sector goods, work and services, repatriation
Depending on your needs, we are able by selling state-owned bank shares on a of profits, including dividends,
to offer assistance ranging from per- competitive basis to investors with the repayment of loans, payment of travel
appropriate experience and knowledge. expenses, and certain non-commercial
request advisory services to complex
It is expected that privatization will transfers. Individuals generally may also
structuring advice and complete
increase the efficiency of banking buy and sell foreign currency at banks
outsourcing of the HR and payroll activities, and the availability and subject to certain limitations.
function. quality of financial services, and will
enable modern international banking The law specifically prohibits payments
standards, information technology and in foreign currency in the territory
4.3. Banking regulations software products to be introduced to of Uzbekistan for goods (work and
the Uzbek banking system. services), with certain exceptions, such
The banking system of Uzbekistan
as payments made using international
consists of the Central Bank of the
payment cards in accordance with
Republic of Uzbekistan and commercial EY has a team of professionals who
international practice. Prices and tariffs
banks. Banking operations in Uzbekistan can advise on setting up a bank in
for goods (work and services) sold
must be licensed by the Central Bank of Uzbekistan and relevant compliance locally and the charter capital of local
the Republic of Uzbekistan. requirements and provide full support companies may only be set in local
International financial institutions with the financing of local businesses currency. In addition, state duties and
also operate in Uzbekistan to a certain by international financial institutions. other mandatory payments may be
extent, providing financing to local charged, withheld and paid only in local
businesses in the form of loans or equity currency.
investments.
Doing business in Uzbekistan 255 EY
in Uzbekistan
26 Doing business in UzbekistanEY was one of the first international advisory firms to commence operations in Tashkent with the opening of
its office in 1995. Our firm in Uzbekistan is part of our EMEIA practice, encompassing Europe, the Middle East,
India and Africa. In Uzbekistan, EY has an office in Tashkent.
Supporting our clients Contact information
in a dynamic landscape For more information on how EY can help you find your bearings in Uzbekistan’s tax
At EY, we know that businesses in and legal and business terrain, please contact one of the following EY leaders:
emerging markets need innovative
thinking and practical advice in order ASSURANCE STRATEGY & TRANSACTIONS
to succeed. We support our clients Anvar Azamov Timur Pulatov
by facilitating their sustainable Partner, Head of Uzbekistan Practice Partner, Strategy & Transactions
development strategy and creating new Tel: +998 (78) 140 6482 Tel: + 7 727 258 5960
growth opportunities in today’s dynamic Anvar.S.Azamov@uz.ey.com Timur.Pulatov@kz.ey.com
economic environment.
TAX SERVICES ADVISORY
Doniyorbek Zulunov Ruta Makareviciute
Our major services Partner, Tax Services, Central Asia Partner, Consulting, Central Asia
Tel: +998 (78) 140 6482 Tel: +998 (78) 140 6482
• A
► ssurance Tel: + 7 727 258 5960 Ruta.Makareviciute@uz.ey.com
• T
► ax & Law Doniyorbek.Zulunov@kz.ey.com
• S
► trategy & Transactions
LAW SERVICES OFFICE LOCATION
• C
► onsulting Dinara Tanasheva Mustaqillik prospect, 75,
Partner, Law Services, Tashkent, 100000, Uzbekistan
Head of Tax & Law, Central Asia Tel: +998 78 140-6482
Tel: + 7 727 258 5960 e-mail: eytashkent@uz.ey.com
Dinara.S.Tanasheva@kz.ey.com
Doing business in Uzbekistan 276 Appendix 28 Doing business in Uzbekistan
A.1. Double tax treaties
The following table lists the withholding rates under Uzbekistan’s tax treaties.
Dividends (l), Interest (l), Royalties, Dividends (l), Interest (l), Royalties,
Payee resident in Payee resident in
% % % % % %
Austria 5/15 (a) 10 5 Kyrgyzstan 5 5 15
Azerbaijan 10 10 10 Latvia 10 10 10
Bahrain 8 8 8 Lithuania 10 10 10
Belarus 15 (k) 10 15 Luxembourg 5/15 (b) 10 5
Belgium 5/15 (a) 10 5 Malaysia 10 10 10
Bulgaria 10 10 10 Moldova 5/15 (a) 10 15
Canada 5/15 (a) 10 5/10 (e) Netherlands (l) 5/15 (b) 10 10
China 10 10 10 Oman 7 7 10
Czech Republic 5/10 (b) 5 10 Pakistan 10 10 15
Egypt 5/10 (b) 10 12 Poland 5/15 (c) 10 10
Estonia 5/10 (b) 5 10 Romania 10 10 10
Finland 5/15 (a) 5 0/5/10 (f) Russian Federation 10 10 0
France 5/10 (a) 0/5 (d) 0 Saudi Arabia 7 7 10
Georgia 5/15 (b) 10 10 Singapore 5 5 8
Germany 5/15 (b) 5 3/5 (g) Slovak Republic 10 10 10
Greece 8 10 8 Slovenia 8 8 10
Hungary 10 10 10 Spain 5/10 (b) 5 5
India 10 10 10 Switzerland 5/15 (c) 0/5 (d) 5
Indonesia 10 10 10 Tajikistan 5/10 (b) 10 10
Iran 8 10 5 Thailand 10 10/15 (k) 15
Ireland 5/10 (a) 5 5 Turkey 10 10 10
Israel 10 10 5/10 (h) Turkmenistan 10 10 10
Italy 10 5 5 Ukraine 10 10 10
Japan 5/10 (b) 5 0/5 (i) United Arab Emirates 5/15 (b) 10 10
Jordan 7/10 (b) 10 20 United Kingdom 5/10 (a) 5 5
Kazakhstan 10 10 10 Vietnam 15 (k) 10 15
Korea (South) 5/15 (b) 5 2/5 (j) Non-treaty countries 10 10 20
Kuwait 5/10 (b) 8 20
Doing business in Uzbekistan 29(a) The lower rate applies if the beneficial owner of the dividends is a company (g) The 3% rate applies to royalties paid for the use of, or the right to use,
that owns at least 10% of the payer of the dividends. copyrights of scientific works, patents, trademarks, designs or models, plans,
or secret formulas or processes, as well as for the disclosure of industrial,
(b) The lower rate applies if the beneficial owner of the dividends is a company commercial, or scientific knowledge. The 5% rate applies to royalties paid for
that owns at least 25% of the payer of the dividends. certain cultural works.
(c) The lower rate applies if the beneficial owner of the dividends is a company (h) The 5% rate applies to royalties paid for certain cultural works (with
that owns at least 20% of the payer of the dividends. exceptions).
(d) The 0% rate applies to interest with respect to the following: (i) The 0% rate applies to royalties paid for the use of, or the right to use,
• Loans made, guaranteed or insured by the government of the other copyrights of literary, artistic or scientific works, including motion picture
contracting state or an instrumentality or agency thereof films.
• Sales on credit of industrial, commercial or scientific equipment (j) The 2% rate applies to royalties for the use of, or the right to use, industrial,
• Sales on credit of merchandise between enterprises commercial, or scientific equipment.
• Bank loans (k) The domestic withholding tax rate for dividends and interest in Uzbekistan is
(e) The 5% rate applies to royalties paid for certain cultural works (with 10%. Consequently, the withholding tax rate of 15% for dividends and interest
exceptions) as well as for the use of, or the right to use, computer software under treaties does not apply to payments made by Uzbek companies.
or patents or for information concerning industrial, commercial or scientific (l) Under the Protocol to the Netherlands-Uzbekistan double tax treaty,
experience (know-how), with exceptions. withholding tax rates may potentially be reduced to zero if certain conditions
(f) The 0% rate applies to royalties for the use of, or the right to use, computer are met.
software, patents, designs or models, or plans. The 5% rate applies to royalties
paid for the use of, or the right to use, secret formulas or processes, or for
information concerning industrial, commercial or scientific experience (know-
how). The 10% rate applies to royalties paid for trademarks or certain cultural
works.
30 Doing business in UzbekistanA.2. List of countries with 11. Individual administrative units of 32. Niue (New Zealand)
United Kingdom of Great Britain
preferential tax regimes and Northern Ireland:
33. Panama
Approved by Decree No. 2467 of the 34. Republic of Kiribati
1) Channel Islands (Guernsey,
State Tax Committee, State Customs
Jersey, Sark, Alderney) 35. Republic of Portugal (only with
Committee and Central Bank directors
regards to Madeira Islands)
of 12 June 2013 (as amended on 2) Isle of Man
12 October 2020) 36. Samoa
12. Grenada
1. American Samoa 37. San Marino
13. Guatemala
2. Andorra 38. Seychelles
14. Djibouti
3. Antigua and Barbuda 39. Saint Kitts and Nevis
15. Dominican Republic
4. Aruba 40. Saint Lucia
16. Dominica
5. Bahamas 41. Saint-Martin Island
17. Cyprus
6. Barbados 42. Saint Vincent and the Grenadines
18. People’s Republic of China,
7. Belize only with regards to: 43. United States of America (only with
regard to the following areas):
8. Brunei Darussalam 1) Siangan (Hong Kong)
1) US Virgin Islands
9. Vanuatu 2) Aomyn (Macao)
2) Puerto Rico
10. United Kingdom of Great Britain 19. Costa Rica
and Northern Ireland (only with 3) Wyoming State
20. Cook Islands (New Zealand)
regard to the following areas):
4) Delaware State
21. Liberia
1) Anguilla
44. Tonga
22. Lebanese Republic
2) Bermuda Islands
45. Fiji
23. Liechtenstein
3) British Virgin Islands
46. France (only with regard to the
24. Mauritius
4) Montserrat following areas):
25. Malaysia (only with regard to
5) Gibraltar 1) Kerguelen Islands
Labuan Island)
6) Chagos Island 2) French Polynesia
26. Maldives
7) Pitcairn Islands 47. Sri Lanka
27. Malta
8) South Georgia and South 48. Jamaica
28. Marshall Islands
Sandwich Islands
49. Uruguay
29. Monaco
9) Turks and Caicos Islands
50. Palau (Pacific Ocean)
30. Nauru
10) Cayman Islands
51. Philippines
31. Netherlands Antilles
Doing business in Uzbekistan 31You can also read
