juris.hq
TaxesUpdated 30.08.2026

Do double-tax treaties reduce Uzbek withholding?

Short answer

Yes — applied at source, if the recipient proves residence before the payment.

PriorityTreaties outrank the Code — where an international treaty sets other rules, the treaty’s rules apply (Tax Code, Arts. 2, 6 — lex.uz ↗)
At sourceThe payer applies the relief directly — the tax agent may apply the exemption or reduced rate itself, no advance clearance (Tax Code, Art. 357 — lex.uz ↗)
PapersA residence certificate by the payment date — legalised or apostilled, a notarised copy, or the foreign authority’s web-published document (Tax Code, Art. 358 — lex.uz ↗)
Real ownerThe beneficial-owner test guards it — relief follows the person with the actual right to the income, not a conduit in a treaty country (Tax Code, Art. 6 — lex.uz ↗)
What the law provides

Uzbekistan’s treaty network plugs straight into the withholding machinery: the Code gives international treaties priority, and the tax agent — the Uzbek company paying — applies the treaty’s exemption or reduced rate at source, provided the recipient hands over a document confirming tax residence in the treaty state no later than the payment date. The certificate can be a legalised or apostilled original, a notarised copy, or the electronic document published on the foreign authority’s own web resource — the web-published form needs no legalisation. (Tax Code, Arts. 357–358 — lex.uz ↗)

Two guards temper it. For dividends, interest and royalties the recipient must be the beneficial owner — the person with the actual right to use and dispose of the income, judged by functions and risks, not by the certificate alone. And where the non-resident’s work has in fact created a permanent establishment here, the agent cannot apply treaty exemption to its income. Relief not taken at source is not lost: the tax withheld can be reclaimed under the Code’s refund chapter. (Tax Code, Arts. 6, 357 — lex.uz ↗)

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