Uzbekistan Transfer Pricing Documentation Requirements
Uzbekistan requires transfer pricing documentation for controlled transactions, which the tax authority may request in respect of any such transaction, produced within 30 days. The regime is developing toward the OECD model, with enforcement currently running through the general document-production rules.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
TP documentation Required | Controlled transactions (documentation requestable for any such transaction) | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | UZ / RU | Yes (general fine for non-provision of requested documents) |
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Scope of the documentation obligation
Where a taxpayer’s transactions are treated as controlled, the Uzbek tax authorities may request transfer pricing documentation in respect of any such transaction. The documentation is produced within 30 days of a request. The framework is developing toward the OECD model, and the operative obligation is the documentation described here rather than a formal Master File and Local File structure.
Distinctive features of the Uzbek regime
The defining feature of the Uzbek regime is that enforcement currently operates through the general rules on document production rather than through a transfer-pricing-specific penalty. A taxpayer that does not provide the documents requested by the tax authorities bears the general monetary liability for non-provision of requested documents, so the consequence of missing documentation is the standard one for any failure to respond to a request. As the regime is still developing, detailed thresholds and practice points are not yet settled in the captured rules, and there is no Country-by-Country reporting obligation in the regime as captured.
Benchmarking and comparables
Uzbekistan’s transfer pricing practice is developing toward the OECD approach, and an entity with controlled transactions is expected to support its pricing with a comparability analysis consistent with that framework. Detailed local practice on the choice of comparables, the testing period, and the frequency of fresh searches continues to take shape as the regime matures.
Frequently asked questions
How is non-compliance enforced in Uzbekistan?
Enforcement currently runs through the general rules on document production. A taxpayer that does not provide the documents requested by the tax authorities bears the standard monetary liability for non-provision, rather than a transfer-pricing-specific penalty.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.