Double Taxation in Uzbekistan: Tax Treaties (DTT) 2026

Elena Vasyukova

Partner, Accounting & Tax practice

DipIFR, CPA Uz, ACCA Affiliate · chief accountant, 15+ years in international companies

Last updated 2026-08-20 · 17 min read

✓ Facts verified against primary sources (lex.uz, soliq.uz)

Last updated 2026-08-20 · 17 min read · ✓ Facts verified against primary sources (lex.uz, soliq.uz)

↻ Updated: 2026-08-20

Double taxation in Uzbekistan is removed by double taxation treaties (DTTs): an international treaty legally outranks the Tax Code, so the treaty withholding rate may be lower than the domestic one — or the income may be exempt entirely. Uzbekistan has more than 50 such treaties in force. Below we explain how treaty priority works, what rates DTTs with Russia, Kazakhstan, Germany and others give, under which conditions a treaty can be applied, which exemptions work even without a DTT, and what happens if the residency certificate arrives after the payment has already been made.

What is double taxation and why it arises

Double taxation is when the same income is taxed twice: in the country where it arose (the source country) and in the country where the recipient is a tax resident and must pay tax on worldwide income. A classic example: an Uzbek company pays dividends to a shareholder resident in Germany. Uzbekistan withholds tax at source on payment, and Germany taxes the same income at home. Without a relief mechanism the money is taxed on both sides of the border.

Uzbekistan solves this with two instruments. The first is bilateral double taxation treaties (DTTs/DTAs), which allocate the right to tax the income between the two countries and reduce the rate at source. The second is the priority principle: if an international treaty sets rules other than domestic tax law, the treaty rules apply (part 2, art. 2 of the Tax Code of Uzbekistan). The application of treaties is detailed in article 6 of the Tax Code.

How many double taxation treaties does Uzbekistan have?

Uzbekistan has signed about 54 double taxation treaties, of which more than 50 are already in force. The network covers key trading partners: Russia, Kazakhstan, China, Germany, the UK, Switzerland, Turkey, the UAE, South Korea and many EU and CIS states. The current official list is maintained by the State Tax Committee and published in the international-cooperation section on soliq.uz.

Why does business need to know this? Because the presence or absence of a treaty directly affects the cost of a cross-border payment. If there is a DTT with the recipient's country and the conditions are met, withholding tax is taken at a reduced rate (or not at all). If there is no treaty, the full domestic rate applies: 10% on dividends and interest, 20% on royalties and services, 6% on freight (art. 353 of the Tax Code).

What rates do treaties give: a country matrix

The core rule: a treaty does not cancel the tax — it reduces or reallocates it between countries. The exact rate depends on the type of income (dividends, interest, royalties) and the treaty's conditions — for instance, the ownership share. Below is the domestic rate against DTT rates for jurisdictions popular with Uzbek business.

How to read the matrix. On dividends many treaties cut the rate from 10% to 5% with a substantial holding (e.g. Germany, the UK, Switzerland). On interest several treaties give 0% under certain conditions (loans between related parties, government credits). On royalties the treaty with Russia zero-rates them, while most others reduce them from the domestic 20% to 5–10%. The exact figure always comes from the text of the specific treaty, not from a "market average".

Under what conditions can a DTT be applied?

A treaty benefit is not automatic. Article 357 of the Tax Code sets four mandatory conditions that must be met simultaneously before the tax agent may apply a reduced rate or exemption.

Condition 1: a taxable object must exist under the Tax Code. A DTT applies only to income listed in art. 351 (for legal entities) or arts. 365–366 (for individuals). If the payment does not constitute taxable income in Uzbekistan, no DTT — and no certificate — is needed at all.

Condition 2: a treaty in force with the non-resident's country. Confirm that the recipient's country is covered by a valid DTT and that the specific income type (dividends, interest, royalties, services) falls within its scope.

Condition 3: residency certificate — no later than the payment date. Under part 3 of art. 357 the recipient must provide the tax agent with a residency certificate on or before the payment date. Formal requirements for the document are set in art. 358 of the Tax Code.

Condition 4: beneficial ownership of the income. Under parts 4–5 of art. 357 the treaty benefit does not apply if the non-resident acts as an intermediary or has limited authority over the income. "Conduit" entities that merely pass income through cannot use the DTT.

How to apply a DTT in practice: the residency certificate

For the tax agent in Uzbekistan to withhold at the DTT rate, the income recipient must prove they are a tax resident of the partner country. The key document is a tax residency certificate issued by the competent authority of their country. Under part 3 of article 357 of the Tax Code it must be provided to the tax agent no later than the date the income is paid. Formal requirements for the certificate itself are set in article 358 of the Tax Code.

1. 1

   Check the treaty exists and its text

   Confirm a treaty between Uzbekistan and the recipient's country is in force and covers your income type (dividends, interest, royalties, services).

2. 2

   Request the residency certificate in advance

   The recipient obtains the certificate in their country. The tax agent needs it no later than the payment date — plan the timing ahead.

3. 3

   Check the beneficial owner

   Under art. 6 and parts 4–5 of art. 357 of the Tax Code the benefit does not apply if a resident uses the treaty in the interest of another person who is not a resident of the partner country (anti-abuse rule).

4. 4

   Withhold at the DTT rate

   With a valid certificate the agent withholds at the treaty rate (or not at all) and keeps the calculation and documents for a possible audit.

What happens if the residency certificate is received after payment?

This is one of the most common practical situations: the contract is signed, the money has been sent, and the residency certificate from the foreign partner arrives a few days later. Here is what happens in that case.

At the time of payment — tax is withheld at the full domestic rate (10%, 20% or 6%) because no valid certificate was on file when the transfer was made.

After receiving the certificate — the non-resident may apply for a refund of the excess withholding. The mechanism is set out in part 6 of article 357 of the Tax Code: the non-resident (through the tax agent or directly) files an application with the tax authority, attaching the residency certificate and proof of entitlement to the treaty benefit. The refund follows the procedure of Chapter 12 of the Tax Code:

• the tax authority reviews the application within 10 working days;
• notice of the decision is sent within 3 days of it being made;
• the actual refund is issued within 15 days from the date the application is received.

The refund goes to the tax agent's account (the Uzbek company), which then transfers the amount to the non-resident with currency conversion.

Bottom line: receiving the certificate after payment is a workable situation, but it creates extra burden — filing an application, waiting for the decision, and tracking the refund. The better approach is to secure the certificate before the payment.

Withholding tax exemptions that work without a DTT

The absence of a treaty does not always mean the full domestic rate applies. The Tax Code of Uzbekistan provides several mechanisms to reduce or eliminate withholding tax without a DTT — based purely on domestic rules.

1. No taxable object (art. 351 of the Tax Code). If the payment does not fall within the list of taxable income from Uzbekistan sources, no withholding tax arises at all — and no certificate is needed. Typical cases:

• remote IT services performed entirely outside Uzbekistan (if they do not constitute a permanent establishment);
• international freight on routes between two non-Uzbek points with no involvement of Uzbek territory;
• representative expenses incurred in favour of a non-resident (part 3 of art. 369 of the Tax Code).

2. Zero rate under art. 353 of the Tax Code. Sub-clauses 4 and 5 of part 1 of article 353 establish a zero profit-tax rate for certain categories of non-resident income. This is a domestic exemption — it applies regardless of whether a DTT exists. The specific income types are listed in the text of art. 353 on lex.uz.

3. Temporary sector benefits (art. 483 of the Tax Code). Article 483 contains a catalogue of temporary tax benefits introduced by Presidential decisions for specific industries. Under Law №ЗРУ-1108 of 25 December 2025 several benefits apply from 2026. Examples current as of 2026:

• zero profit-tax rate on sales of electricity generated by renewable-energy installations (Law №ЗРУ-1014 of 24 December 2024);
• VAT, property-tax and profit-tax exemptions for satellite-communications operators (until 1 January 2031);
• for operators of electric-vehicle charging stations (until 1 January 2028): property tax and land tax on charging stations and their land plots levied at 1%; profit-tax exemption where charging income represents ≥50% of annual revenue; charging income deductible from the turnover-tax base (Law №ЗРУ-1108 of 25 December 2025).

These benefits apply to all qualifying entities — residents and non-residents alike — provided the sectoral criteria are met, and do not require a DTT.

Credit and refund: how double taxation is removed in the residence country

A treaty removes double taxation from both sides. In Uzbekistan it cuts the rate at source. In the recipient's residence country the credit method usually applies: tax already paid in Uzbekistan is credited against the tax due at home — up to the amount of the home tax on that income. As a result the same income is not taxed at the full rate twice.

For the credit, the recipient needs documentary proof that tax was actually withheld in Uzbekistan. So a correctly prepared calculation and a statement of withheld tax matter not only for the Uzbek side but also for the foreign credit.

A separate case is the refund of excess withholding. If the benefit existed but the certificate did not arrive by the payment date, the excess tax can be refunded under part 6 of article 357 of the Tax Code, confirming residency after the fact. The procedure works but is time-consuming — so it is better to settle it with a certificate in advance.

Common mistakes when working with treaties

Mistakes in applying DTTs almost always result in additional assessments against the tax agent — the Uzbek paying company, not the foreign recipient. Below is what lowers the risk and what leads to it.

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