2017乌兹别克斯坦税务简报（英文版）

Uzbekistan International Tax Highlights 2017 Summary

Core Content Overview

This summary outlines the key aspects of the tax system in Uzbekistan, focusing on corporate and personal taxation, foreign exchange regulations, and compliance requirements as of 2017. The document provides a comprehensive overview of the legal framework governing tax obligations and incentives for both residents and nonresidents.

Corporate Taxation

Taxable Entities and Residency

• Residency: An entity is considered a resident if it has completed state registration in Uzbekistan.
• Taxable Income: Includes business and investment income, calculated as aggregate income minus deductible expenses.
• Profit Tax Rate: General rate is 7.5%, with 15% for banks and additional income tax for mobile operators if profitability thresholds are met.
• Nonresident Entities: Subject to 10% profit tax on a net basis if they have a permanent establishment (PE) in Uzbekistan.

Special Regimes and Incentives

• Unified Tax: Available for micro-firms and small entities at 5%, lower for companies in remote regions.
• Simplified Taxation: Replaces profit tax, VAT, property tax, land tax, and social infrastructure taxes.
• Industry-Specific Rates: Entertainment companies and those with over 60% lease income from sales outlets are taxed at 30%.
• Tax Exemptions: Certain industries and activities (e.g., software companies, exporters) may be eligible for temporary exemptions or reduced tax bases.

Dividends and Capital Gains

• Dividends: Exempt from profit tax in the hands of residents and nonresidents with a PE, but subject to 10% withholding tax.
• Capital Gains: Treated as ordinary income and taxed at 7.5% when gains are realized from the sale of shares.

Losses and Carryforward

• Losses may be carried forward for 5 years, up to 50% of taxable income per year. Carryback is not allowed.

Withholding Tax

• Dividends: 10% withholding tax (reducible under tax treaties).
• Interest: 10% withholding tax (reducible under tax treaties).
• Royalties: 20% withholding tax (reducible under tax treaties).
• Other Withholdings: 10% on insurance premiums and 6% on telecommunications and transportation services.

Compliance and Penalties

• Tax Year: Calendar year.
• Filing Requirements: Resident companies file quarterly returns by the 25th day of the following month, and annual returns by 15 February.
• Penalties: Ranging from USD 33 to USD 100 for late filings or registration failures, with a 0.033% daily penalty for late tax payments.

Anti-Avoidance Rules

• Transfer Pricing: Tax authorities may apply a market rate to related-party transactions.
• Disclosure: Some rules apply under National Accounting Standards (NAS).

Personal Taxation

Taxable Individuals

• Residency: Individuals are residents if they are domiciled in Uzbekistan or physically present for at least 183 days in a 12-month period.
• Taxable Income: Includes wages, salaries, benefits (e.g., training, childcare), and other income (e.g., prizes, awards).
• Nontaxable Income: Healthcare benefits, inheritances, insurance premiums and repayments.

Tax Rates and Filing

• Progressive Rates: From 0% to 23%.
• Filing: Individuals must file income declarations by 1 April, with payments due by 1 June of the following year.
• Withholding: Employment income and passive income are taxed at source.

Social Contributions

• Unified Social Contribution: 15% for micro-firms and small entities, 25% otherwise.
• Pension Fund: Employers must withhold 8% of gross salary for resident employees.

Other Taxes and Charges

Value Added Tax (VAT)

• Taxable Transactions: Supply of goods and services, import of goods.
• Standard Rate: 20%.
• Exempt Services: Transport for passengers (excluding taxis), medical, educational, and financial services.
• Zero-Rated Supplies: Goods exported for hard currency, services for processing goods for export, and international transportation.
• Registration: Micro-firms and small enterprises can opt for voluntary VAT registration.

Real Property Tax

• Rate: 5% on fixed assets, double rate for equipment not timely installed.
• Property Tax: 1.7% to 2.9% on real property value.

Social Infrastructure and Road Fund

• Social Infrastructure Development Tax: 8% on net profit after corporate profit tax.
• Road Fund Contributions: 1.4% of gross revenue (quarterly for micro-firms and small entities, monthly otherwise).

Stamp Duty

• Levied on court claims, notarial actions, and state registration of legal entities.

Tax Authorities and Treaties

• Tax Authorities: State Tax Committee, State Customs Committee, Ministry of Finance.
• Tax Treaties: Uzbekistan has signed over 50 bilateral tax treaties.
• Tax Law Source: Tax Code, Presidential and Cabinet Decrees.

Contact Information

• Andrey Tyo: antyo@deloitte.uz
• Bakhtiyor Sufiev: bsufiev@deloitte.uz

Additional Notes

• Deloitte provides audit, consulting, and tax services but does not render professional advice through this communication.
• The document is intended for general information only.