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Amendments have been introduced to the list of attachments submitted together with the Withholding Tax report. Tax agents applying a withholding tax exemption or a reduced treaty rate under Uzbekistan’s double tax treaties with respect to dividends, interest, and royalties are now required to attach supporting documentation confirming that the non-resident recipient is the beneficial owner of the relevant income.
This requirement is provided in Articles 6 and 357 of the Tax Code of the Republic of Uzbekistan. At the same time, the Tax Code does not prescribe a specific form and (or) content of such confirmation. Tax agents should therefore request documentation to ensure sufficient evidence is available to substantiate a beneficial ownership test when applying treaty benefits.