What is the withholding rate on dividends and interest to a non-resident?

Dividends and interest paid to a non-resident are subject to withholding tax at 10%. Under a double taxation treaty (DTT) the rate may be lower. Source: Art. 353 of the Tax Code, lex.uz. Valid as of 2026-06-15.

What rate applies to royalties and services of a non-resident?

Royalties, as well as income from services (including management and consulting), rent and other income are taxed at source at 20%. Freight income (international transport) is 6%. Source: Art. 353 of the Tax Code, soliq.uz. Valid as of 2026-06-15.

What is a permanent establishment and when does it arise?

A permanent establishment (PE) is a place of business through which a non-resident operates in Uzbekistan. If one arises, income is taxed not at source but as PE profit, with reporting and corporate profit tax. Governed by Art. 36 of the Tax Code. Valid as of 2026-06-15.

Taxes for non-residents in Uzbekistan 2026: withholding tax

Q: How does a DTT reduce withholding tax?

A double taxation treaty (DTT) may set a reduced rate or an exemption. To claim relief, the non-resident must provide a tax residency certificate from their country before the income is paid. Source: Art. 357 of the Tax Code. Valid as of 2026-06-15.

Withholding tax for non-residents in Uzbekistan: dividends and interest 10%, freight 6%, royalties and services 20%, plus DTTs and permanent establishment.

Last updated 2026-06-15

Yaroslav Kolesov

Partner, Accounting & Tax practice

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

Last updated 2026-06-15 · 9 min read

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

Last updated 2026-06-15 · 9 min read · ✓ Facts verified against primary sources (lex.uz, soliq.uz)

Taxes for non-residents in Uzbekistan are withheld at source by the paying Uzbek company: dividends and interest at 10%, freight at 6%, royalties and services at 20%, with a double taxation treaty able to reduce the rate. Who withholds, how much and when, how to reduce the rate under an international treaty, and the point at which a non-resident becomes a permanent establishment — let's break it down by income type.

Valid as of 2026-06-15

Withholding rates and the procedure for applying treaties are governed by the Tax Code of Uzbekistan and may change. Before paying a non-resident, check the current version on lex.uz and soliq.uz.

Who is a non-resident and why "source" matters

For taxes in Uzbekistan, what matters is not citizenship but tax residency. A foreign company with no permanent presence in the country is a non-resident. But if it earns income "from a source in the Republic of Uzbekistan" — for example, from an Uzbek company — that income falls within Uzbek taxation.

The key feature: the non-resident files nothing with the tax authority. The tax is withheld and paid on its behalf by the Uzbek company that pays the income — acting as a tax agent. This is "withholding tax at source": it is deducted from the payment before the money leaves the country. The object of taxation and the list of taxable non-resident income are set out in Article 351 of the Tax Code, and the rates in Article 353.

Non-resident

A foreign company with no permanent presence in Uzbekistan that earns income from an Uzbek source.

Tax agent

The paying Uzbek company: it is the one that withholds the tax and remits it to the budget.

At source

The tax is deducted from the payment before the money is transferred to the non-resident — no separate return for them.

What are the withholding tax rates for non-residents in Uzbekistan?

The main thing for a foreign investor and for the paying Uzbek company to know: the rate depends not on the amount but on the type of income. The Tax Code sets different rates for dividends, interest, freight, royalties and services.

Вид дохода / IncomeСтавка у источника / WHT

Dividends

payment to a non-resident shareholder

10%

Interest

on loans and debt obligations

10%

Insurance and reinsurance

premiums paid to a non-resident

10%

Freight (international transport)

transport and forwarding services

Royalties

licences, trademarks, software

20%

Services, rent, other income

including management and consulting

20%

20% is the most common surprise

Many Uzbek companies forget that paying a foreign contractor for services (consulting, marketing, management, IT outsourcing) is subject to withholding tax at 20%. If the contract does not say who bears this tax, in practice it has to be grossed up — and the payment becomes a quarter more expensive. Check this before signing.

These are the domestic rates. They apply when there is no treaty, or when the non-resident has not confirmed its residency. If a double taxation treaty is in force between Uzbekistan and the non-resident's country, the rate is often lower — more on that below.

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DTTs: how a treaty reduces the tax

Uzbekistan has concluded double taxation treaties (DTTs) with dozens of countries. The point of a treaty is to stop the same income being taxed twice — both in Uzbekistan and in the recipient's country. For withholding tax this means one thing in practice: the rate may be reduced or the income exempted.

For example, dividends to a non-resident are taxed at 10% domestically, while many DTTs cut this to 5%; interest is fully exempt under a number of treaties; royalties may be taxed at 5–10% instead of 20%. The exact rate depends on the wording of the specific treaty and its conditions (such as the size of the shareholding).

1
Check whether a DTT exists
Confirm that a double taxation treaty is in force between Uzbekistan and the non-resident's country and that it covers your income type.
2
Obtain a residency certificate
The non-resident must provide a tax residency certificate issued by the competent authority of its country — this is the key document for relief.
3
Apply the reduced rate
With a valid certificate, the tax agent withholds at the treaty rate (or not at all) instead of the domestic rate.
4
Keep the documents
Store the certificate and the calculation: in an audit the tax authority may request proof of the right to relief.

No certificate — domestic rate

Treaty relief is not automatic. If you do not hold a valid tax residency certificate of the non-resident at the time of payment, tax is withheld at the full domestic rate (10% / 20% / 6%). Tax already withheld can later be reclaimed, but that is a separate procedure — it is easier to obtain the certificate in advance.

Permanent establishment: when the rules change

Withholding tax applies as long as the non-resident does not operate through a permanent establishment (PE) in Uzbekistan. A permanent establishment is, in simple terms, a fixed place of business: an office, a construction site, an agent authorised to conclude contracts, or providing services in the country beyond a set period. The concept of a PE is set out in Article 36 of the Tax Code.

If a PE arises, the logic changes fundamentally: income is taxed not at source at a flat rate but as the profit of the permanent establishment — with income and expenses calculated, reporting filed and corporate profit tax paid. For a foreign company this effectively means a full tax presence.

Without a permanent establishment

withholding tax

The non-resident earns "passive" or one-off income. The Uzbek company withholds a fixed percentage on payment. The non-resident files no reporting.

With a permanent establishment

profit tax

The activity is regular and tied to a place. Income is taxed as PE profit: income/expense accounting, returns, and profit tax in Uzbekistan.

The line between a one-off service and a permanent establishment is one of the most contested topics. A long project, seconded staff, a warehouse, a dependent agent — all of these can trigger PE recognition and additional assessments. So for any extended presence in Uzbekistan, the structure is worth modelling in advance.

We'll assess permanent establishment risk for your project

Who is responsible for withholding tax, and by when?

The responsibility lies with the tax agent — the Uzbek company paying the income. It must correctly classify the income, apply the right rate (domestic or treaty), withhold the tax and remit it to the budget. If the agent fails to withhold, the tax authority will pursue the agent, not the foreigner — a common and costly mistake.

What reduces risk

A tax residency certificate of the non-resident obtained in advance.
Clear classification of the income in the contract (services, royalties, interest).
A withholding clause in the contract stating who bears the tax.
Checking whether a DTT exists, and its wording, before payment.

What leads to assessments

Paying without withholding when there is no residency certificate.
Applying a reduced treaty rate "on trust", without the document.
Misclassifying services as "non-taxable".
Ignoring the signs of a permanent establishment.

Common mistakes in payments to non-residents

What to avoid

Not building withholding tax into the deal budget and discovering the 20% after the fact; applying a treaty rate without a residency certificate; assuming "the foreigner pays the tax" (by law the Uzbek agent withholds it); confusing a one-off service with a permanent establishment; taking rates from outdated sources. Verify the facts on lex.uz and soliq.uz — or let us handle the payments.

Non-resident taxes in Uzbekistan: the essentials

Withholding tax is withheld by the paying Uzbek company (the tax agent), not by the non-resident.
Domestic rates: dividends and interest 10%, freight 6%, royalties and services (including consulting and management) 20%.
A DTT can reduce the rate or exempt the income, but a tax residency certificate is needed before payment.
With a permanent establishment, income is taxed as PE profit rather than at source.
Responsibility for withholding lies with the agent — a mistake means assessments and penalties.
Verify all rates and conditions against the current Tax Code (Arts. 351, 353, 357, 36).

Frequently asked questions

What is withholding tax on a non-resident?+

It is tax on a non-resident's income that the paying Uzbek company (the tax agent) withholds and remits to the budget at the moment of payment. The non-resident files no return itself.

What is the rate on dividends and interest to a non-resident?+

The domestic rate is 10%. Under a double taxation treaty the rate may be lower (for example 5% on dividends or an exemption on interest).

What rate applies to royalties and services?+

Royalties, services (including management and consulting), rent and other income are 20%. Freight in international transport is 6%.

How do I apply a reduced DTT rate?+

The non-resident must provide a tax residency certificate from its country before payment. Then the tax agent withholds at the treaty rate, or not at all.

What happens if withholding tax is not withheld?+

The tax authority will pursue the tax agent — the paying Uzbek company — not the foreign recipient, for assessments and penalties. That is why withholding is critical.

When does a permanent establishment arise?+

When a non-resident operates regularly through a fixed place in Uzbekistan (office, construction site, dependent agent, long-running services). Then income is taxed as PE profit rather than at source.

Who pays withholding tax under the contract?+

By law the Uzbek agent withholds it. But who bears the economic burden should be set out in the contract, otherwise the tax has to be grossed up on top of the payment.

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