Acted for foreign client on transfer pricing rules in Uzbekistan for Indian-owned groups — Tax Advisory · Uzbekistan
Client. An Indian-owned corporate group with an existing presence in Russia seeking to establish a subsidiary in Uzbekistan as part of a broader regional expansion across CIS markets.
Background. The group's proposed intra-group arrangements — including management service fees, intercompany financing, and goods supply between the Indian parent and the proposed Uzbek entity — triggered potential exposure under Uzbekistan's transfer pricing legislation. Uzbekistan has progressively developed its transfer pricing framework, and the applicable rules for controlled transactions with foreign related parties carry documentation obligations and adjustment risks that differ materially from the Indian parent's home-jurisdiction expectations. The matter arose at the term-sheet stage, before any commercial agreements were finalised.
Our role. Counsel reviewed the proposed intra-group structure against the transfer pricing rules applicable in Uzbekistan to cross-border controlled transactions, assessed which transaction types would fall within the controlled transactions regime, identified the documentation requirements, and analysed the pricing methodologies most defensible under the Uzbek framework. The analysis was provided in advance of contract signing.
Outcome. [PLACEHOLDER — operator to replace with real outcome] Exposure identified before signing and contractually allocated. The group entered the market with pricing arrangements and documentation obligations structured to reflect the applicable regulatory position in Uzbekistan.
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