UZBEKISTAN · TAX ADVISORY
Transfer Pricing in Uzbekistan
Bond Stone advises multinational corporations on transfer pricing in Uzbekistan — the arm's length principle applicable to controlled transactions between an Uzbek entity and its foreign affiliates, documentation requirements, and structuring management fees, royalties, and intercompany loans to comply with Uzbek transfer pricing rules and withstand tax authority scrutiny.
Primary authority: Tax Code of the Republic of Uzbekistan (transfer pricing provisions, as amended). Verify at 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
Transfer pricing framework — Uzbekistan
Uzbekistan's transfer pricing rules are embedded in the Tax Code and require that transactions between related parties be priced on arm's length terms — as if conducted between independent parties in comparable circumstances. The Uzbek transfer pricing framework is broadly consistent with OECD Transfer Pricing Guidelines, though local documentation requirements and audit practices have specific features. The retention period for transfer pricing documentation was reduced from 5 to 3 years from 2024 under recent Tax Code amendments.
Controlled transactions — scope
Uzbek transfer pricing rules apply to: transactions between an Uzbek entity and its foreign affiliates; transactions with entities in preferential tax jurisdictions (a list set under the Tax Code); and transactions that the tax authority determines are structured to shift profit out of Uzbekistan. Management fees, technical services, royalties, intercompany loans, and goods supply between related parties are all subject to transfer pricing scrutiny.
Transfer pricing methods
The Uzbek Tax Code recognises the following methods for determining the arm's length price: Comparable Uncontrolled Price (CUP); Resale Price Method; Cost Plus Method; Transactional Net Margin Method (TNMM); and Profit Split Method. The most appropriate method depends on the nature of the transaction and the availability of comparable data. Bond Stone advises on method selection and coordinates with the client's transfer pricing specialists on the economic analysis.
Documentation requirements
Uzbek taxpayers conducting controlled transactions above the materiality threshold are required to maintain transfer pricing documentation demonstrating arm's length pricing. The documentation must be available for submission to the Uzbek Tax Committee on request. From 2024, the mandatory retention period is 3 years. Bond Stone advises on Uzbek documentation requirements and coordinates with the multinational group's global transfer pricing policy to ensure local compliance.
Management fees and technical services
Management fees and technical services paid to foreign parent companies are among the most scrutinised intercompany transactions in Uzbekistan. The Uzbek tax authority examines whether the services were actually provided, whether the fee is arm's length, and whether the deduction is supported by appropriate documentation. Bond Stone advises on structuring and documenting management service arrangements to satisfy Uzbek tax authority requirements.
Preferential jurisdiction transactions
Transactions with entities in jurisdictions on Uzbekistan's preferential (low-tax) list are subject to enhanced transfer pricing scrutiny regardless of whether the counterparty is a related party. Bond Stone advises on identifying whether a counterparty's jurisdiction is on the Uzbek list and on the enhanced documentation obligations that apply to such transactions.
Experience
Bond Stone has provided tax advisory as part of investment structuring mandates in Uzbekistan. Client confidentiality is maintained across all matters.
Transfer Pricing · Uzbekistan · Corporate
Management Fee Structure
Advising on structuring management fee payments from an Uzbek subsidiary to its foreign parent — arm's length fee determination, service documentation (service agreement, evidence of delivery), WHT on fee payments, and CIT deductibility.
Transfer Pricing · Uzbekistan · IP
Royalty — IP Licence Pricing
Advising on transfer pricing for a royalty payment under an IP licence from a foreign group entity to an Uzbek licensee — arm's length royalty rate (domestic WHT 20%, reduced to 5–10% under applicable DTT), TNMM analysis, documentation, and WHT planning.
Transfer Pricing · Uzbekistan · Finance
Intercompany Loan — Arm's Length Rate
Advising on arm's length interest rate for an intercompany loan from a foreign parent to an Uzbek subsidiary — comparable uncontrolled price analysis, documentation, WHT on interest (10% domestic rate), and CIT deductibility of interest payments.
Transfer Pricing · Uzbekistan · Compliance
Documentation Preparation
Preparing transfer pricing documentation for a multinational group's Uzbek subsidiary — local file covering management services, intercompany loans, and goods supply, with 3-year retention period compliance.
Transfer Pricing · Uzbekistan · Corporate
Preferential Jurisdiction — Enhanced Scrutiny
Advising on enhanced transfer pricing documentation obligations for transactions with a counterparty in a jurisdiction on Uzbekistan's preferential list — documentation requirements and risk mitigation strategy.
Transfer Pricing · Uzbekistan · Dispute
Tax Authority Challenge — Response
Advising an Uzbek subsidiary on responding to a transfer pricing query from the Uzbek State Tax Committee — reviewing the authority's comparables analysis, preparing a defence, and negotiating the adjustment.
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 transfer pricing in Uzbekistan.
info@bondstonelaw.com
+7 (701) 729 76 72 — Almaty
Request a Confidential Consultation ← Withholding Tax & DTT VAT in Uzbekistan → ← Tax Advisory Hub
