A practical guide to VAT and indirect taxes in Uzbekistan in the transport and logistics sector

Unlike the EAEU bloc, where VAT harmonisation rules govern cross-border services and transit freight under a single intergovernmental framework, Uzbekistan operates a fully autonomous indirect tax regime under its own Tax Code. For foreign transport operators, freight forwarders, and logistics companies entering the Uzbekistan market or routing cargo through it, this distinction is consequential: VAT registration thresholds, zero-rating conditions for international transport, excise duties on motor fuel, and the treatment of agency and forwarding fees all follow national rules that can differ materially from what practitioners familiar with Russian or Kazakh tax law might expect.

What to prepare before you start

Before working through the steps below, confirm the following for your Uzbekistan operation:

• Whether your entity has or requires a local legal presence (representative office, branch, or subsidiary)
• The nature of your revenue streams: domestic haulage, international freight, transit, freight forwarding fees, or a combination
• Whether you supply services to Uzbekistan-resident customers or to non-resident counterparties billed from abroad
• The categories of fuel, rolling stock, or infrastructure on which you may incur Uzbekistan excise or road-use charges
• Your current VAT-taxable turnover in Uzbekistan and whether it meets the registration threshold

The starting point for any foreign transport or logistics business in Uzbekistan is the VAT registration threshold. Under Uzbekistan's Tax Code, VAT registration is mandatory for entities whose taxable turnover exceeds the prescribed annual threshold. As of the current tax period, this threshold sits at one billion Uzbek soums; it is adjusted periodically, and operators should verify the current figure at the outset of each calendar year.

For foreign legal entities without a permanent establishment in Uzbekistan, VAT obligations arise differently. A non-resident providing services to Uzbekistan-based customers may trigger a reverse-charge obligation on the recipient: the Uzbekistan-resident customer is required to self-assess and remit VAT on the payment. However, where the non-resident operates through a branch, representative office, or subsidiary registered in Uzbekistan, it is treated as a taxable person and must register for VAT independently once the threshold is crossed.

Practically, many international freight operators structure Uzbekistan operations through a locally registered entity to avoid threshold ambiguity and to facilitate VAT credit recovery on input costs. The registration itself is administered through the Uzbekistan tax authority's electronic portal. Timelines from submission to certificate issuance typically run two to four weeks, though this varies with the completeness of the documentation submitted.

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Uzbekistan's Tax Code distinguishes between taxable supplies at the standard VAT rate, zero-rated supplies, and exempt supplies. The standard rate is twelve per cent. For transport and logistics operators, the zero-rating provisions are of particular practical importance.

International freight transport services are generally zero-rated under Uzbekistan law, provided that the relevant conditions are met. The key condition is that the transportation involves the carriage of goods across the Uzbekistan border: that is, export freight originating in Uzbekistan, import freight arriving in Uzbekistan, or transit freight passing through Uzbekistan territory. The zero rate applies to the primary carrier and, under the prevailing interpretation, to ancillary services that are directly connected to the qualifying international movement, such as loading, unloading, and transhipment directly incident to the cross-border journey.

Domestic transportation, by contrast, is subject to VAT at the standard twelve per cent rate. Where a single operator provides a combination of domestic and international legs within a single contract, the tax treatment of each leg must be assessed separately. Freight forwarders who act as agents, earning a commission fee for arranging transport rather than themselves providing it, are taxed on the commission income at the standard rate, not on the gross freight value; this distinction matters considerably for VAT base calculation.

Exempt supplies in the transport context include certain socially significant passenger transport services operated on regulated domestic routes. Commercial freight is not within this exemption.

Cross-border road and rail freight between Uzbekistan and Russia, and between Uzbekistan and Kazakhstan, is commercially significant given the volume of goods moving along the Central Asian corridors. The tax treatment turns on the direction and documentation of the movement.

For Uzbekistan-registered carriers transporting goods from Uzbekistan to Russia or Kazakhstan, and for carriers transporting goods in the reverse direction into Uzbekistan, the international transport zero-rate applies at the Uzbekistan end of the transaction. The carrier must hold documentary evidence of the cross-border character of the service: the international consignment note (CMR for road, railway waybills for rail), customs declarations confirming border crossing, and the contract of carriage specifying origin and destination.

Russia and Kazakhstan are both EAEU members. Their own VAT treatment of the same transaction will follow EAEU protocol rules on the taxation of services related to goods. This creates a structuring consideration for operators active on both sides: the tax position in Uzbekistan and the tax position in Russia or Kazakhstan are governed by different legal frameworks, and a position that achieves zero-rating at one end does not automatically produce the same outcome at the other. Foreign operators with entities in both jurisdictions should map the VAT consequences in each country independently.

Transit freight passing through Uzbekistan en route between two third countries is also eligible for the zero rate, subject to appropriate customs transit documentation. The Uzbekistan customs transit regime requires a transit declaration and, in most cases, a financial guarantee or bond.

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Uzbekistan levies excise duties on certain goods produced or imported into the country, and several of these are directly relevant to transport and logistics operators. Motor fuel — petrol, diesel, and liquefied petroleum gas — is subject to excise duty. For fleet operators importing fuel or purchasing it domestically, excise is embedded in the price paid to the supplier; it is not recoverable as an input credit in the same way as VAT. Operators should therefore factor excise-inclusive fuel costs into their operating cost models from the outset.

Imported vehicles and rolling stock may attract both customs duties and, for certain categories, excise duty at the point of import. The rates and applicable categories are set out in the customs tariff schedule and are updated periodically. Temporary importation regimes exist for foreign-registered vehicles transiting Uzbekistan or providing international transport services into the country, and these typically allow duty-free entry for a defined period, provided the vehicle departs within the permitted window.

Road user charges and axle-load levies apply to heavy goods vehicles operating on Uzbekistan roads. These are not taxes in the strict sense but represent a compliance cost that operators must register for and discharge. Non-compliance carries administrative penalties and may result in delay or refusal of entry at border crossing points.

VAT in Uzbekistan is administered through a mandatory electronic invoicing system. VAT-registered entities are required to issue electronic invoices (e-invoices) through the state platform for all VAT-taxable supplies. Paper invoices do not constitute valid VAT documentation for credit or refund purposes.

For transport and logistics operators, this means that every domestic taxable supply must be accompanied by a properly formatted e-invoice issued through the platform. For zero-rated international transport, the e-invoice must state the zero rate and be accompanied by the supporting documentary evidence described in Step 2 above. The failure to issue a compliant e-invoice, or to retain the supporting cross-border documentation, is the most common reason that VAT credit claims are challenged or rejected by the Uzbekistan tax authority in the transport sector.

Foreign companies operating through a local entity must ensure that their accounting and invoicing systems are integrated with the Uzbekistan e-invoicing platform from the moment of VAT registration. This integration is typically handled by local accounting software providers or via API connection. The timeline for integration should be factored into the overall market entry project plan.

For logistics operators whose output VAT is predominantly zero-rated (because the majority of their supplies are international freight), input VAT on domestic purchases, fuel, warehousing, and other operating costs may create a persistent VAT credit balance. Uzbekistan's Tax Code provides a mechanism for refunding excess input VAT, but the process involves submission of a refund application, documentary audit by the tax authority, and in practice can extend to several months from application to receipt of funds.

Operators should build this timing into their cash-flow projections. In practice, companies that carry significant VAT credit balances often opt to carry them forward against future output VAT liabilities rather than applying for cash refunds, where the business model permits. The choice depends on the scale of domestic taxable supplies and the anticipated trajectory of the operation.

A desk audit or field audit by the tax authority is a standard feature of the refund process. Operators should ensure that all supporting documentation – contracts, invoices, customs documents, bank payment records – is systematically retained and accessible. The Uzbekistan tax authority has the right to audit the period covered by the refund claim; adequate record-keeping substantially reduces the risk of partial disallowance.

• [Uzbekistan legal and regulatory overview for foreign investors](/jurisdictions/uzbekistan/)
• [Tax framework for foreign companies in Uzbekistan](/jurisdictions/uzbekistan/tax/)
• [Company formation and market entry in Uzbekistan](/jurisdictions/uzbekistan/company-formation/)

Q: Does a foreign freight forwarder without a physical presence in Uzbekistan need to register for VAT there?

A: A non-resident freight forwarder providing services to Uzbekistan-resident clients may trigger a reverse-charge VAT obligation on the recipient, rather than a direct registration requirement for the non-resident itself. However, where the non-resident's activities in Uzbekistan constitute a permanent establishment under the Tax Code, direct registration becomes mandatory once the taxable turnover threshold is crossed. The analysis turns on the nature and regularity of the activities performed in-country, including whether local personnel or facilities are involved. Foreign operators should assess their permanent establishment exposure before committing to a service model.

Q: Is transit cargo passing through Uzbekistan subject to VAT or customs duties?

A: Transit cargo passing through Uzbekistan between two third countries is generally not subject to Uzbekistan VAT on the transport service, provided the operator can document the transit character of the movement with a valid transit customs declaration and the goods do not enter domestic free circulation. Customs duties are suspended under the transit regime, subject to the provision of a financial guarantee or equivalent security. Road freight operators using the transit corridor should be aware that procedural compliance – accurate transit declarations, timely departure from Uzbekistan, vehicle documentation – is as important as the substantive tax position, since procedural failures can trigger duty assessments even where the underlying exemption applies in principle.

Q: How does Uzbekistan's VAT treatment of international transport compare with the EAEU rules that apply in Russia and Kazakhstan?

A: The substantive outcome – zero-rating for international transport – is broadly similar, but the legal basis and procedural requirements differ. In EAEU member states, the zero-rate for international transport services and the documentary conditions for claiming it are governed by EAEU protocols and inter-state agreements. In Uzbekistan, which is not an EAEU member, the same outcome is achieved entirely under domestic legislation, with documentary requirements set by the Uzbekistan Tax Code and implementing regulations rather than by any supranational instrument. In practice, this means that operators active in both Uzbekistan and EAEU jurisdictions must maintain separate documentary packs for each jurisdiction, as the specific documents required to support zero-rating may differ even for the same physical freight movement.

Vetrov & Partners is a Russian boutique law firm established in 2009. The firm is recognised by Pravo-300 – Russia's principal legal directory – for eight consecutive years, and is listed as a trusted adviser by the German Consulate General in Novosibirsk.

The firm's tax and cross-border advisory practice covers inbound foreign investment structures across Russia and the wider CIS region, including Uzbekistan. For matters requiring Uzbekistan-qualified counsel, the firm works with trusted regional partners. With over 1,000 matters handled since inception, the team ensures direct partner involvement on every engagement, with no delegation to junior fee-earners.

Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

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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.

— Nodira Yusupova Contributing Regional Analyst — Uzbekistan, Vetrov & Partners vetrovpartners.com/contributions/