Amendments to the Tax Code of the Republic of Uzbekistan have been signed

Pursuant to the Law of the Republic of Uzbekistan dated 25 December 2025 No. ZRU-1108 “On Amendments and additions to certain legislative acts of the Republic of Uzbekistan in connection with the adoption of the main directions of tax and budget policy for 2026” (hereinafter – the Law), amendments to the Tax Code of the Republic of Uzbekistan were adopted.

The provisions of the Law introduce amendments to the framework governing transfer pricing control, which are set out below.

I.   Tax Audits

An amendment has been introduced to Article 137 “Types of Tax Audits,” pursuant to which a transfer pricing formation audit has been added(supplemented subparagraph four part three to Article 137).

II.    Controlled transactions

Transactions between related parties involving the provision of an interest-free loan are no longer recognized as controlled transactions for transfer pricing purposes, provided that all of the following conditions are met:

•  if all parties and beneficiaries involved in such transactions are tax residents of the Republic of Uzbekistan;
• obligations under these loan agreements are fulfilled only on the territory of the Republic of Uzbekistan. (supplemented by part 10 to Article 180)"

III.  Our team

• Best international practices combined with leading local expertise in Uzbekistan will support the achievement of your objectives – all key specialists of the EY team possess extensive international experience working with leading companies in Uzbekistan and across the region.
• Active dialogue with governmental authorities, business associations, and international organizations – our team actively represents clients’ interests in working groups on transfer pricing and taxation matters involving both the state and the private sector. With us, you will always be informed of ongoing developments and be able to assert your position in discussions on key issues.
• Comprehensive support and unified accountability – we provide clients with end-to-end assistance: developing supply chain structures and intra-group pricing policies, minimizing risks, supporting tax audits, and, where necessary, defending clients in litigation. During transfer pricing projects, we also train client specialists, transferring our knowledge and experience.