Double Taxation in Uzbekistan: Tax Treaties (DTT) 2026
How Uzbekistan's double taxation treaties work: treaty priority over the Tax Code, reduced DTT withholding rates, residency certificates and the credit method.
Last updated 2026-06-28
Yaroslav Kolesov
Partner, Accounting & Tax practice
DipIFR, CPA Uz, ACCA Affiliate · chief accountant, 15+ years in international companies
Last updated 2026-06-28 · 10 min read · ✓ Facts verified against primary sources (lex.uz, soliq.uz)
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, which residency certificate you need, and how to recover tax if the benefit was applied too late.
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.
Source country
Uzbekistan, where the income arose (dividends, interest, royalties, services). Withholding tax is taken here.
Treaty priority
If the DTT says otherwise than the Tax Code, the treaty governs — explicitly set in part 2, art. 2 of the Tax Code.
Residence country
Where the recipient pays on worldwide income. Tax already paid in Uzbekistan is credited here.
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.
Withholding rates: domestic vs treaty (DTT)
Dividends · interest · royalties for major partner countries
No DTT (domestic)
Dividends10%
Interest10%
Royalties20%
Russia
Dividends10%
Interest0–10%
Royalties0%
Kazakhstan
Dividends10%
Interest0–10%
Royalties10%
Germany
Dividends5–15%
Interest0–5%
Royalties3–5%
United Kingdom
Dividends5–10%
Interest5%
Royalties5%
Switzerland
Dividends5–15%
Interest0–5%
Royalties5%
China
Dividends10%
Interest0–10%
Royalties10%
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".
A range is no reason to guess
Rates shown as "5–15%" mean the treaty has conditions inside (holding threshold, type of loan, beneficial owner). You cannot apply the lower bound "just in case": on audit the tax authority will demand justification. Verify the specific treaty clause — or let us run the calculation.
How to apply a DTT in practice: the residency certificate
A treaty benefit is not automatic. 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
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
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
Check the beneficial owner
Under art. 6 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
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.
No certificate on the payment date — domestic rate
If there is no valid certificate when the money is transferred, tax is withheld at the full domestic rate (10% / 20% / 6%). This is not a "penalty" but a rule: the treaty benefit is simply not confirmed. The withheld tax can be refunded later, but that is a separate procedure.
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.
With the DTT applied
optimalCertificate provided on time → reduced rate at source in Uzbekistan + credit of the balance in the residence country. No double taxation.
No DTT / no certificate
costlierDomestic 10–20% at source. A credit in the residence country is possible but, without a treaty, may be limited — the burden is higher.
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.
What lowers the risk
- The residency certificate is obtained before the payment date and meets art. 358.
- The rate is taken from the specific treaty clause, not an "average".
- The beneficial owner of the income is checked (art. 6).
- The contract states who bears the withholding tax.
- Calculation and documents are kept for audit and the foreign credit.
What leads to assessments
- Applying a reduced rate without a certificate "on trust".
- Using the lower bound of a range without justifying the conditions.
- Routing income through a "conduit" resident with no real beneficiary.
- Believing the tax "is paid by the foreigner" (the agent withholds by law).
- Rates from outdated or unofficial sources.
Related articles
- Taxes for non-residents in Uzbekistan 2026: withholding tax
- Taxes in Uzbekistan 2026: rates, regimes, what to choose
- International settlements in Uzbekistan: how to pay abroad
- How to pay foreign contractors from Uzbekistan
Key points on double taxation in Uzbekistan
- Double taxation is removed via DTTs and the priority of an international treaty over the Tax Code (part 2 art. 2, art. 6).
- Uzbekistan has signed about 54 treaties, 50+ in force (Russia, Kazakhstan, Germany, the UK, Switzerland, China and more).
- Domestic withholding rates: dividends and interest — 10%, royalties and services — 20%, freight — 6%; DTTs reduce or zero them.
- The reduced rate applies only with a residency certificate filed with the agent no later than the payment date (art. 357).
- In the residence country, double taxation is removed by crediting tax already paid in Uzbekistan.
- Excess withholding can be refunded (part 6 art. 357), but obtaining the certificate in advance is simpler.
FAQ
What is double taxation in simple terms?+
It is when the same income is taxed twice — in the country where it arose (Uzbekistan) and in the country where the recipient is a tax resident. Treaties (DTTs) and a credit for tax paid remove this double burden.
Which prevails — the Tax Code or the double taxation treaty?+
The treaty. Under part 2 of article 2 and article 6 of the Tax Code, international treaty rules have priority over domestic tax law, so the DTT rate may be below the domestic one.
How many DTTs does Uzbekistan have?+
About 54 treaties signed, 50+ in force — including Russia, Kazakhstan, Germany, the UK, Switzerland, China. The current list is published by the State Tax Committee on soliq.uz.
What document is needed for a reduced DTT rate?+
A tax residency certificate of the recipient, issued by the competent authority of their country. Under part 3 of article 357 the agent must hold it no later than the date the income is paid.
What happens if you apply a DTT rate without a certificate?+
The benefit is deemed unconfirmed: on audit the tax is recomputed at the domestic rate and assessed against the agent — the Uzbek paying company. So the certificate is needed before payment.
How do you refund tax if the DTT was not applied on time?+
If the benefit existed, the excess withholding is refunded under part 6 of article 357, confirming the recipient's residency. The procedure works but takes time.
Who is responsible for correct withholding at source?+
The tax agent — the Uzbek company paying the income. It is the one the tax authority will assess on a mistake, not the foreign recipient.
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Yaroslav Kolesov
Partner, Accounting & Tax practice
DipIFR, CPA Uz, ACCA Affiliate · chief accountant, 15+ years in international companies
BizReg (Ustores LLC, Tashkent) helps foreigners set up companies in Uzbekistan turnkey — registration, legal address, bank account and accounting. 1000+ registrations over 15 years.
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