UZBEKISTAN · TAX ADVISORY
Corporate Income Tax in Uzbekistan
Bond Stone advises international investors and multinational corporations on corporate income tax (CIT) in Uzbekistan — the standard 15% rate, sector-specific rates, SEZ and IT Tech Park CIT exemptions, and structuring investment activity to optimise the CIT position. The CIT rate will not be increased before 1 January 2028 under Presidential Decree No. UP-229.
Primary authority: Tax Code of the Republic of Uzbekistan (as amended, most recently for 2026 by Law No. ZRU-1108 dated 25 December 2025); Presidential Decree No. UP-229 dated 27 December 2024. Authority: lex.uz
Uzbekistan — Tax Context 2026
15%
CIT standard rate — no increase before 2028
12%
VAT standard rate — no increase before 2028
10%
WHT on dividends to non-residents
54
Double taxation treaties in force (March 2026)
Key Framework
Standard CIT rate — 15%
The standard corporate income tax rate in Uzbekistan is 15% — applicable to most Uzbek legal entities and foreign legal entities operating through a permanent establishment in Uzbekistan. CIT is levied on taxable profit — gross income less deductible expenses as defined by the Tax Code. Presidential Decree No. UP-229 dated 27 December 2024 provides that CIT and VAT rates will not be increased before 1 January 2028.
Sector-specific CIT rates
The following sector-specific CIT rates apply under the Tax Code: 20% — banks, producers of polyethylene granules, taxpayers whose main activity is mobile communication services, and profit from services of markets and shopping complexes (Tax Code, Art. 337); 2% (with social tax at 1%) — businesses manufacturing garments and knitwear, footwear and leather goods (from 1 January 2025 to 1 January 2028, if all conditions are met, including at least 70% of income from such products; Decree No. UP-229, para. 2, as amended by Decree No. UP-174 of 19 September 2025); 50% reduction — entities in the electrical industry where at least 80% of revenue derives from electrical product sales (until 1 January 2027). A 50% reduction of the standard rate is available to a taxpayer whose aggregate income first exceeds UZS 10 billion after 1 September 2022, for that tax period and the next, subject to conditions (Tax Code, Art. 337).
IT Tech Park — CIT exemption
Residents of the Uzbekistan IT Tech Park — established by Presidential Decree No. UP-5099 dated 30 June 2017 — are entitled to income tax exemption until 2028. From 1 January 2028 to 1 January 2040, residents with exports above 50% of income and qualifying IT education providers are exempt from all taxes except VAT. From 1 February 2025 to 1 January 2030, non-resident companies with export services above USD 10 million a year, other than tax residents of treaty states, are exempt on income from IT services to IT Tech Park residents (Tax Code, Art. 483).
SEZ CIT exemptions
SEZ participants are exempt from CIT by amount invested: USD 3–5 million for 3 years, USD 5–15 million for 5 years, USD 15 million or more for 10 years, running from commissioning of the facility and only for the activities in the investment agreement. Taxpayers that become participants from 1 April 2026 receive accelerated depreciation for the same periods instead (Tax Code, Arts. 473 and 474).
Deductible expenses — key items
Deductible expenses for CIT purposes include: business expenses incurred in generating taxable income; depreciation on fixed assets at rates prescribed by the Tax Code; salary costs and social tax; interest on borrowings (subject to transfer pricing limits on related-party debt); and professional fees. Non-deductible items include dividends paid to shareholders, penalties and fines, and expenses without supporting documentation.
Permanent establishment — non-residents
Foreign companies conducting business activities in Uzbekistan without a registered entity may create a permanent establishment (PE) — triggering CIT in Uzbekistan on profits attributable to the PE, a further 10% on net profit after tax, which a treaty may reduce (Tax Code, Art. 347), and a duty to register with the tax authority (Art. 130). The PE risk threshold and profit attribution rules follow OECD guidelines as adapted in the Uzbek Tax Code. Bond Stone advises foreign companies on PE risk assessment and on structuring activities to manage PE exposure in Uzbekistan.
Experience
Bond Stone has provided tax advisory as part of investment structuring mandates in Uzbekistan. Client confidentiality is maintained across all matters.
CIT · Uzbekistan · Manufacturing · SEZ
CIT Structuring — Manufacturing SEZ
Advising a foreign manufacturer on CIT structuring through an Uzbek SEZ entity — SEZ CIT exemption scope, qualifying activity compliance, separate accounting requirements, and interaction between the SEZ exemption and the standard 15% CIT regime.
CIT · Uzbekistan · Technology
IT Tech Park — CIT Exemption
Advising an IT company on IT Tech Park residency to access the income tax exemption until 2028 — eligibility assessment, exempt activity scope, and ongoing compliance with IT Tech Park operating conditions.
CIT · Uzbekistan · Manufacturing
Sector Rate Analysis — Manufacturing
Advising a foreign manufacturer on the applicable CIT rate for its Uzbek entity — confirming the standard 15% rate applies and identifying any sector-specific rates or incentives available for the specific manufacturing activity.
CIT · Uzbekistan · Corporate
PE Risk Assessment — Services
Advising a foreign services company on PE risk arising from its activities in Uzbekistan — PE threshold analysis under the applicable DTT, profit attribution methodology, and structuring recommendations to manage PE exposure.
CIT · Uzbekistan · Corporate
CIT Deductibility — Intercompany Fees
Advising on CIT deductibility of management fees and technical services paid to a foreign parent — arm's length analysis, documentation requirements, and WHT on service fee payments to the foreign parent entity.
CIT · Uzbekistan · Investment
Investment Contract — CIT Stability
Advising a foreign investor on obtaining an investment agreement with the government of Uzbekistan — CIT rate stability guarantee, qualifying investment threshold, and ongoing compliance with investment agreement conditions.
Investing in Uzbekistan
Uzbekistan — Tax Advantages for Investors
- 15% CIT rate — no increase before 1 January 2028 under Presidential Decree No. UP-229
- Dividends on JSC shares to 31 December 2028 — individuals exempt, non-resident companies 5%
- IT Tech Park — 0% income tax until 2028 for qualifying residents
- 54 DTTs in force — reducing WHT on dividends, interest, and royalties to treaty rates
Uzbekistan — International Financial Centre (Not Yet Operating)
Tashkent International Financial Centre (TIFC)
Constitutional Law No. ZRU-1158 of 13 July 2026 exempts qualified TIFC participants from income tax and social tax on financial services income until 1 January 2076, and excludes large multinational groups from these incentives. The Centre is not yet operating. Bond Stone is monitoring the TIFC Acts that will set the conditions.
Tashkent International Financial Centre — full guide →Why Bond Stone
- Tashkent office — direct engagement with Uzbek tax authorities
- Ranked Legal 500 EMEA and IFLR1000 — Tashkent and Almaty offices
Primary authority: lex.uz
Discuss your Uzbekistan tax matter
Contact Bond Stone for a confidential discussion about corporate income tax in Uzbekistan.
info@bondstonelaw.com
+7 (701) 729 76 72 — Almaty
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