Uzbekistan signs the multilateral convention on mutual administrative assistance in tax matters

On 15 July 2026, at the headquarters of the Organisation for Economic Co-operation and Development (the “OECD”) in Paris, the Republic of Uzbekistan (“Uzbekistan”) signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the “Convention”). According to the OECD’s official announcement dated 15 July 2026, Uzbekistan became the 153rd signatory to the Convention.

We would like to bring attention to the main features of the Convention that, in our opinion, are the most significant from an international tax administration perspective. For a complete understanding of the Convention and its application in Uzbekistan, we recommend referring to the official text of the Convention, the OECD announcement and subsequent domestic ratification documents when adopted.

Key objectives of the Convention

The Convention was developed jointly by the OECD and the Council of Europe in 1988 and amended by Protocol in 2010, as reflected in the official OECD materials on the Convention. With its recent signature, Uzbekistan is taking steps to join an established international framework for cross-border tax cooperation. In particular, the Convention provides a multilateral legal basis for tax cooperation and is broadly aimed at:

• supporting the correct assessment and collection of taxes;
• allowing tax authorities to exchange relevant tax information through agreed procedures;
• strengthening international efforts to combat tax evasion and tax avoidance.

Forms of administrative assistance under the Convention 

The Convention provides for the following forms of cooperation: 

• exchange of information on request — one country may ask another country for tax-related information on specific persons or transactions;
• automatic exchange of information — countries may automatically exchange information for agreed categories of cases and under procedures determined by mutual agreement;
• spontaneous exchange of information — one country may share information with another country without a prior request, where the information may be relevant for tax purposes;
• simultaneous tax examinations — countries may examine, each in its own territory, the tax affairs of persons in which they have a common or related interest;
• tax examinations abroad — in certain cases, representatives of one tax authority may be allowed to participate in part of a tax review in another country;
• assistance in recovery and measures of conservancy — a requested country may recover another country’s tax claims as if they were its own;
• service of documents — tax-related documents may be served through cooperation between competent authorities.

Overall, once the Convention becomes effective for Uzbekistan, the Uzbekistan tax authorities may have broader legal channels for obtaining tax-related information from foreign tax authorities, subject to conditions and applicable procedures established by the Convention.

Entry into force and effective application 

Signing the Convention does not by itself make the Convention fully operational for Uzbekistan. After such signing, Uzbekistan must complete its internal legal procedures to express consent to be bound through parliamentary ratification and such instrument of ratification (acceptance or approval), i.e., the formal legal document by which Uzbekistan officially expresses its consent to be bound by the Convention on the international plane is deposited with one of the Depositaries (OECD or Council of Europe Secretary General).

After all those steps done, the Convention enters into force for the new party (Uzbekistan) on the first day of the month following the expiration of a period of three months after the date of deposit of the instrument. For example, if the instrument is deposited on 15 October 2026, the Convention enters into force for Uzbekistan on 1 February 2027.

Effective use also requires domestic implementing legislation, designation of competent authorities, and operational capacity (secure channels, data protection safeguards, etc.).

So, the exact timing should therefore be monitored through further official updates.

Implications for taxpayers

Although the Convention does not introduce new substantive tax rules, taxpayers should consider the following practical implications once the Convention becomes effective for Uzbekistan:

• cross-border transactions may become more visible to tax authorities through exchange of information mechanisms;

• tax positions reported in Uzbekistan should be consistent with information reported or available in other jurisdictions;

• transfer pricing, financing, royalty, service fee and other cross-border arrangements should be supported by proper agreements, invoices, calculations and evidence of actual substance;

• taxpayers should be ready to explain the business purpose and tax treatment of cross-border arrangements in the event of tax audits or information requests;

• groups with foreign shareholders, foreign bank accounts, foreign service providers or related-party transactions should review whether their documentation is sufficient and internally consistent.

How can EY help?

We would be pleased to assist you in the following areas:

• reviewing withholding tax, treaty relief and beneficial ownership positions in light of increased tax transparency;
• advising on the potential impact of the Convention on existing and planned cross-border structures;
• assisting with the preparation of internal tax risk assessments and practical action plans.

We hope you find this information useful. We would be happy to advise you on these developments in more detail and discuss any questions you may have.