Uzbekistan's transfer pricing regime requires foreign investors and multinational groups transacting with related parties in the country to follow a defined compliance sequence: identify whether a transaction is controlled, apply an arm's length pricing method, prepare supporting documentation, and file a notification with the State Tax Committee where thresholds are exceeded.
H2: What the regime requires
Uzbek tax legislation establishes transfer pricing rules that apply to transactions between related parties where at least one party is resident in Uzbekistan. The core obligation is to price intercompany transactions as if they were concluded between independent parties operating at arm's length. Covered transactions typically include the sale of goods, provision of services, licensing of intellectual property, and financial arrangements such as intercompany loans.
The legislation sets a materiality threshold: transactions below that threshold are not subject to the full documentation and notification requirements, though the arm's length standard still applies in principle. Where the threshold is met or exceeded, the taxpayer must prepare a transfer pricing file – a structured document demonstrating that the pricing method chosen is consistent with arm's length conditions – and submit a notification to the State Tax Committee within the period prescribed by the tax calendar.
H2: How the steps work in practice
In practice, compliance involves four sequential steps. First, the foreign company or its Uzbek subsidiary maps all intercompany transactions conducted during the tax period and classifies them against the controlled-transaction definition in the tax code. Second, the appropriate transfer pricing method is selected – Uzbek legislation recognises internationally standard methods including the comparable uncontrolled price method, the resale price method, and the cost-plus method, among others – and benchmarking analysis is conducted to support the selected price. Third, a transfer pricing file is prepared documenting the functional analysis, the comparability analysis, and the method applied. Fourth, the prescribed notification form is submitted to the State Tax Committee if the aggregate value of controlled transactions exceeds the applicable annual threshold.
Penalties for non-compliance – whether for failure to notify, failure to maintain documentation, or for pricing adjustments raised on audit – are assessed under the general provisions of the Uzbek tax code. The State Tax Committee has expanded its transfer pricing audit capacity in recent years, and controlled transactions between Uzbek entities and related parties in low-tax jurisdictions attract closer scrutiny.
For foreign groups with parallel Russian operations, the compliance picture is more complex: Russia operates its own transfer pricing regime, and intercompany flows touching both jurisdictions require coordinated analysis rather than two independent filings.
If you are assessing Uzbekistan transfer pricing obligations as part of a market entry or restructuring exercise, a review of the [Tax practice for Uzbekistan](/jurisdictions/uzbekistan/tax/) and the broader [Uzbekistan jurisdiction page](/jurisdictions/uzbekistan/) provides useful context on the regulatory environment.
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H2: About Vetrov & Partners
Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. For matters governed by Uzbek law or requiring local admission in Uzbekistan, the firm collaborates with trusted regional counsel. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom
– Nodira Yusupova Contributing Regional Analyst – Uzbekistan, Vetrov & Partners vetrovpartners.com/contributions/
Nodira Yusupova advises on foreign investment and market entry in Uzbekistan, with a focus on tax structuring and regulatory compliance for inbound investors. She contributes regional analysis to Vetrov & Partners on cross-border matters touching Central Asia and Russia.
This publication is provided for informational purposes only and does not constitute legal advice under Russian or any other applicable law. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Vetrov & Partners is a Russian-qualified law firm. For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction. For advice regarding your particular situation, please contact info@vetrovpartners.com.