FMCG Tax Digest (July 2026)

In July 2026, government of the Republic of Uzbekistan (the “RUz”) adopted a number of laws and regulations, which provide for changes in tax administration and support to certain industries. This review deals with those changes, which, in our opinion, may be of practical interest for companies operating in the FMCG sector, including producers, importers, distributors and retail chains.

The previous issues featuring the developments are available at the EY web-site. Tax & Law Alerts | EY - Global.

Changes in the procedure for VAT recovery, invoice issue and tax audit

By its Resolution No. 393 dated 20 July 2026 On Amending and Supplementing Certain Resolutions of the Government of the Republic of Uzbekistan as well as Invalidating Certain Resolutions, which became effective on 21 July 2026, the Cabinet of Ministers of the RUz amended a number of normative acts that regulate the procedure for recovering VAT, issuing e-invoices and exercising tax control.

Some changes affected the desk tax audits. The Resolution includes additional requirements for tax authorities’ consideration of documents and clarifications provided by taxpayers in response to the tax authorities’ requests as well as for the procedure of documenting the results of such consideration.

In addition, the Resolution expands the list of grounds for initiating field tax audits, including individual breaches of legal requirements for digital labeling, non-compliance with the notification requirements for operating activities, instances of operating a business without state registration and instances of long-time storage of certain types of imported food products.

Proposed VAT offset mechanism for imported goods[1]

A draft resolution introducing the mechanism of VAT offset between tax and customs authorities for the purposes of VAT payment on imported goods was published for public discussion. According to the draft resolution, it will be possible to pay import VAT without actually transferring funds to the budget, by offsetting the VAT amounts that are refundable to the taxpayer and validated by the tax authorities.

The proposed mechanism is intended to solve a key challenge faced by importers when the taxpayer is simultaneously eligible for the recovery of significant VAT amounts and obliged to pay VAT on goods for customs clearing purposes. At present, import VAT is generally paid on imported goods simultaneously with customs clearance, while VAT recovery requires undergoing a separate procedure.

According to the draft resolution, once the tax authorities validated the amount of VAT recoverable, the relevant information is automatically delivered to the IT systems of the customs authorities. When importing goods, the taxpayer will be eligible to use the validated recoverable amount to perform the obligation to pay import VAT within the available balance. The mechanism is expected to be implemented by integrating IT systems used by the Tax Committee and the Customs Committee.

The offset is expected to apply exclusively for the VAT amounts verified and validated by the tax authorities under the established procedure. Thus, offset is only allowed for the recoverable amount recognised by the government and available in the relevant IT system.

The implementation of this mechanism is expected to achieve the following results:

• Reduce the business need for additional working capital;
• Accelerate the use of VAT amounts claimed for recovery;
• Reduce finance costs to obtain borrowings to pay import VAT;
• Simplify the interaction between the tax and customs authorities due to the process digitalisation;
• Enhance efficiency of VAT administration for foreign economic activity purposes.

The innovation may have the greatest effect on exporters, producers with a high share of import VAT and companies that are involved in regular import of commodities, equipment, components and other goods in large quantities. For such taxpayers, the mechanism may substantially cut the time gap between the moment when they become eligible for VAT recovery and their actual use of the amounts recovered.

Proposed excise tax for palm oil

In July 2026, RUz announced the initiative to introduce the excise tax for palm oil. The proposal is stated to be aimed at incentivising the use of alternative types of raw materials in food industry and reducing the consumption of products with considerable content of palm oil.

Updated list of agricultural products VATable at the rate of 0%

Joint resolution of the Ministry of Agriculture and the Tax Committee of the RUz No. 3905 On Approval of the List of Zero-Rated Agricultural Products (except for Cotton and Grain) dated 21 July 2026, registered by the Ministry of Justice of the RUz, approved the updated list of agricultural produce grown by agricultural producers that is subject to zero-rated VAT on sales. In particular, the list includes specific exotic fruits (avocado, mango, kiwi, maracuja, pitahaya, rambutan, lychee, pomelo, longan), berry products (blueberry, cranberry, raspberry, strawberry), vegetables and fresh herbs (batata, daikon, rucola, microgreens, asparagus, iceberg lettuce), nuts (macadamia nuts, cashew nuts, hazelnuts, almonds) and a wide range of seedlings, young fruit and ornamental plants, forage crops, seeds and specific types of livestock and fish farming products.

How can EY help?

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

• Advising on the applicability of new legal requirements 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.