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04/25/2026Importing Services from Abroad: How to Avoid Tax Overpayment in Uzbekistan
Step 1. Determine where the service is provided
The first question to ask is: where is this service deemed to be provided — in Uzbekistan or abroad?
According to Article 241 of the Tax Code of the Republic of Uzbekistan, certain services are recognized as provided in the territory of the Republic of Uzbekistan regardless of the geography of their actual performance. This applies, for example, to consulting, legal, marketing, accounting, and IT services if the buyer is located in Uzbekistan.
Step 2. Agent's VAT — who pays and what to do with it
When a foreign company's service is recognized as provided in Uzbekistan, your organization is obliged to calculate and pay VAT to the budget instead of the foreign contractor. This is called "tax agent VAT."
The further fate of this VAT depends on your taxation system:
| Taxation System | What happens to the paid VAT |
|---|---|
| General regime (VAT payer) | VAT is offset — it is effectively not an expense for the business |
| Simplified (Unified Tax Payment / Turnover Tax) | The paid VAT is recognized as a company expense |
Step 3. Corporate income tax at the source — when it arises
In addition to VAT, a payment to a foreign company may be subject to corporate income tax at the source of payment (Art. 351 of the Tax Code, income code 137). This tax is also withheld and remitted by the Uzbek party.
Step 4. Double taxation avoidance agreement
Uzbekistan has entered into double taxation avoidance agreements with 55 states. These agreements allow for the reduction or complete elimination of tax at the source — but only if a number of conditions are met. What needs to be checked:
- Whether your partner's country is on the list of 55 states with which an agreement has been signed.
- Whether the partner has a valid residency certificate with an apostille (Art. 358 of the Tax Code).
- Whether the certificate meets the requirements for form and date.
Step 5. Requirements for a residency certificate
A residency certificate is not just a formality. According to Article 358 of the Tax Code, clear requirements are imposed on it:
The certificate must:
- be issued before the date of income payment to the foreign company;
- have an apostille (or certification in the prescribed manner);
- confirm residency specifically in the tax period when the payment was made, or contain specific dates of validity.
If the certificate is obtained after the transfer of money, the benefit is not applied.
Summary Scheme: How to make a decision
| Situation | Agent's VAT | Tax at source |
|---|---|---|
| Service is recognized as provided in Uzbekistan | Payment is mandatory | Depends on agreement and certificate |
| Partner's country is on the list of 55 states + correct certificate is available | Paid | Reduced or zeroed by agreement |
| Partner's country is NOT on the list of 55 states | Paid | Paid in full (Art. 351) |
| Certificate exists but is issued after payment or with violations | Paid | Paid — the benefit cannot be applied |
Typical mistakes that cost a lot
- Obtaining a certificate "retroactively." A document issued after the payment transfer does not grant the right to a benefit.
- Not checking the list of countries. The double taxation agreement with the partner's country is the first thing to clarify.
- Failure to pay agent's VAT. The obligation arises automatically — regardless of the parties' intentions.
- Thinking that the contract protects against taxes. Both the contract and the certificate are needed, and in the correct order.