Tax and customs incentives granted in the Tashkent International Financial Centre

On 30 March 2026, Decree of the President of the Republic of Uzbekistan No. UP-48 On the Establishment of the Tashkent International Financial Centre (“UP-48”) approved the decision to establish the Tashkent International Financial Centre (the “TIFC”) and the Tashkent International Commercial Court (the “TIFC Court”) within the TIFC.

Article 5 of the Decree provides for the introduction of a special legal framework based on the Constitutional Law of the RUz On the Tashkent International Financial Centre (the “CL”). At the time of preparation of this Alert, the CL is at the draft stage for public discussion purposes. The draft CL provides for amendments and additions to the Constitution of the RUz (New edition approved by the Constitutional Law of the RUz No. ZRU-837 dated 1 May 2023 adopted at the referendum of the Republic of Uzbekistan on 30 April 2023), which evidences that the TIFC legal framework is granted a higher status as compared to other special regimes available in the Ruz. 

Pursuant to UP-48, the Ministry of Investment, Industry and Trade of the RUz was instructed to put forward within one month any proposed amendments and additions arising out of UP-48 to the regulations.

In this review, we summarised provisions of UP-48 and the draft CL that we believe to be most substantial from the taxation perspective. However, we recommend that you study the text of the relevant acts to become fully knowledgeable about the new regulation.

Special legal framework and permitted activities

• The TIFC directly applies common law of England and Wales and equity principles.
• In the territory of the TIFC, it is allowed to provide services and execute transactions related to financial, investment and banking activities, insurance, digital (crypto) assets, securities, payment systems and services, Islamic and green finance, fintech as well as to provide audit, advisory and legal services and carry out other types of activities in accordance with the draft CL.
• In addition, the draft CL provides for the introduction of special tax and customs framework for TIFC bodies, participants, employees, and investment residents for the period until 1 January 2076.
• The suggested measures are aimed at creating a competitive jurisdiction for the development of financial services, capital markets and professional infrastructure in the RUz. In the territory of the TIFC, the tax regime is prescribed by the Tax Code of the RUz (the “TC of the RUz”), except for the following special exemptions.

Corporate income tax and social tax exemptions

• TIFC bodies and their organisations are exempt from corporate income tax, subject to compliance with certain conditions.
• TIFC participants, except for digital asset exchanges, are exempt from corporate income tax and social tax on income received from provision of financial services in the territory of the TIFC, including:
  • Islamic banking services;
  • reinsurance and insurance brokerage services;
  • brokerage, dealer or underwriting services;
  • investment management services for assets of investment funds;
  • any other financial services determined by a TIFC act.
• By a joint document, the TIFC and the Ministry of Economy and Finance of the RUz will determine the rules to account separately for income that is exempt from corporate income tax and income that is subject to taxation. Also, the list of expenses that are deductible for corporate income tax purposes is to be determined by them jointly.
• Exemption from corporate income tax also covers income received from ancillary services provided to TIFC bodies as well as to TIFC participants. Ancillary services include:
  • the services of auditing accounts and providing audit reports and opinions on the financial statements of TIFC participants, the funds established in the TIFC, or the companies listed on any TIFC exchange;
  • the services of auditing accounts and providing audit reports and opinions to verify compliance by TIFC participants;
  • any other non-financial services or activities that are supervised by the Tashkent Financial Services Authority (TFSA).
• Legal entities are exempt from corporate income tax on income in the form of:
  • profits from the sale of securities listed on the official list of a stock exchange;
  • profits from the sale of shares or stakes in the capital of TIFC participants;
  • dividends* and interest from securities listed, on the day of their accrual, on the official list of a stock exchange;
  • dividends from shares or stakes in the capital of TIFC participants.

*The exemption shall apply to dividends on securities that were traded on a stock exchange in accordance with the criteria determined by a joint act of the TIFC and the Ministry of Economy and Finance of the RUz.

Personal income tax exemption

• Foreign nationals who are employed by a TIFC participant or TIFC body and provide qualifying financial services are exempt from personal income tax on income derived from labour activity within the TIFC.
• Income received as payment for labour of resident individuals of the RUz under employment contracts and independent contractor agreements with the TIFC participant or TIFC body are subject to personal income tax at the rate 7%.
• Individuals are exempt from personal income tax on income received in the form of:
  • profits from the sale of securities listed on the official list of a stock exchange;
  • profits from the sale of shares or stakes in the capital of TIFC participants;
  • dividends* and interest from securities listed, on the day of their accrual, on the official list of a stock exchange;
  • dividends from shares or stakes in the capital of TIFC participants;
  • sources outside the RUz, if the natural persons are TIFC investment residents and are recognised as residents of the RUz for the purposes of the TC of the RUz. A TIFC investment resident must make a mandatory payment to the budget for the issuance of a document confirming that the person is a resident of the RUz in the manner and amount provided for by the TC of the RUz.

Value added tax (VAT) exemption

• Financial services provided by TIFC participants are exempt from VAT (the list of such services is similar to the list for corporate income tax purposes).
• Work and services provided by foreign persons to a TIFC body or its organisation where the place of sale of such work or services is RUz are not recognised as turnover related to purchase of work and services from a non-resident.
• The following funds are not recognised as sales turnover for goods, work and services that is subject to value added tax:
  • budget funds received by the TIFC Authority in the form of a targeted transfer in accordance with the budget legislation of the RUz; and
  • money received by the TIFC bodies from the TIFC Authority in the form of a targeted transfer.

Property tax and land tax exemptions

• For facilities located in the territory of the TIFC, the TIFC bodies and TIFC participants are exempt from:
  • legal entities’ property tax;
  • land tax.

No customs duties imposed

• No customs duties or other levies shall be imposed on the property of TIFC bodies, TIFC participants, TIFC employees, or TIFC investment residents imported from abroad for use or consumption in the territory of the TIFC.
• On or after 1 January 2076, no customs duties or other levies shall be imposed on property previously imported into the territory of the TIFC.

Tax administration

• The TIFC administrative bodies have the right to adopt regulations to be applied in the territory of the TIFC – in relation to civil, corporate, and commercial laws, finance, banking, taxation, public procurement, labour law and protection of personal data.
• Tax issues arising between tax authorities, the TIFC and TIFC participants are regulated by the TIFC documents.
• Tax administration by, and interaction of, the state tax authorities with the TIFC bodies and TIFC participants is expected to be determined by joint acts of the TIFC and the Ministry of Economy and Finance of the RUz.

What you should be focused on

• Application of exemptions requires accounting separately for qualifying and non-qualifying income and expenses.
• The list of specific financial and ancillary services will be updated by the TIFC acts.
• Tax administration and control procedures are not yet detailed and require monitoring of regulations.

How can EY help?

We would be happy to assist you in such areas as:

• Advising on the applicability of new legal requirements and benefits to your company;
• Assessing the impact of these developments on the existing business structures, including taxation of existing and planned transactions;
• Revising and updating the company’s tax accounting policies to reflect these developments;
• Drafting queries to the respective regulatory authorities on the issues of application of these legal standards that may require clarification.

We hope that you will find this information useful. We will be glad to advise you on these developments in more detail and discuss them with you if there are any questions.