News
12/03/2025What tax rates and tax consequences are applicable to non-residents in Uzbekistan?
Articles of the Tax Code regulate the procedure of taxation, obligations, and tax rates for non-residents, including activities conducted through a permanent establishment.
Regulatory Provisions
- Article 33 — information about resident and non-resident legal entities.
- Article 347 — taxation specifics of non-resident income through a permanent establishment.
- Article 339 — procedure for filing tax reports by non-residents.
- Article 340 — deadlines for fulfilling tax obligations.
- Item 5 of Article 349 — payment of profit tax before terminating the activities of a permanent establishment.
Non-deductible Expenses of Non-Residents (Article 348)
- Royalties, fees, and payments for using the property or intellectual property of the non-resident.
- Services provided by the non-resident to their own permanent establishment.
- Interest on loans granted by the non-resident to their permanent establishment.
- Expenses not related to income generated through the permanent establishment.
- Administrative and managerial expenses not related to the activity of the permanent establishment.
Taxation Without a Permanent Establishment
Income of non-residents not related to a permanent establishment is regulated by Article 351 (Part 2, Chapter 50).
Tax Rates for Non-Residents (Article 353)
| # | Income Type | Rate (%) |
|---|---|---|
| 1 | Dividends and interest | 10 |
| 2 | Insurance premiums | 10 |
| 3 | International telecom services and freight transportation | 6 |
| 4 | Income from loans for investment projects (foreign financial institutions) | 0 |
| 5 | Services related to correspondent accounts and international payment cards | 0 |
| 6 | Other income | 20 |
Comparison of Tax Rates
| # | Tax Type | Residents | Non-Residents |
|---|---|---|---|
| 1 | Income tax | 12% | 12% |
| 2 | VAT | 12% | 12% |
| 3 | Turnover tax | 4% | 4% |
| 4 | Dividend tax | 5% | 10% |
| 5 | Social tax | 12% | 12% |
Total Income of a Permanent Establishment Includes
- Income from the non-resident’s activities through the permanent establishment.
- Income from owning, using, or disposing of the permanent establishment’s property.
- Income of the non-resident, including foreign branches, related by activity to the permanent establishment.
- Other Uzbekistan-sourced income connected to the permanent establishment.
- Income sourced outside Uzbekistan related to the permanent establishment’s activity.