Transfer Pricing in Uzbekistan: What You Need to Know
Taxes · Published: 2026-03-28 · Updated: 2026-04-27 · Reading time: 9 min
Transactions between related companies are under close scrutiny of Uzbek tax authorities.
Prepared by the auditors of Leader Audit (CAP, CIPA, DipIFR). Sources: Tax Code of Uzbekistan, Ministry of Finance of the Republic of Uzbekistan.
Transfer pricing (TP) is the setting of prices in transactions between interdependent (related) companies. In Uzbekistan, as in most countries, the tax authorities keep a close watch on such transactions, because there is a risk that companies use them to shift profits into lower-tax jurisdictions or between related parties for the purpose of optimization.
What qualifies as a controlled transaction
Under the Tax Code of the Republic of Uzbekistan, the following are recognized as controlled transactions:
- Transactions between interdependent parties (companies within the same group, affiliated parties)
- Transactions with residents of countries on the "blacklist" of offshore jurisdictions
- Foreign-trade transactions in exchange-traded commodities (oil, metals, agricultural products)
- Transactions exceeding the established turnover thresholds
When transfer pricing documentation is required
Preparing transfer pricing documentation is mandatory for controlled transactions when the thresholds for the transaction amount and/or the company's overall turnover are exceeded. The specific thresholds change over time — check the current values in the version of the Tax Code of the Republic of Uzbekistan now in force.
Methods for determining the market price
The Tax Code of the Republic of Uzbekistan recognizes five methods for determining the market price — the same as those in the OECD standards:
- Comparable uncontrolled price method (CUP) — comparison with the prices of similar goods on the open market
- Resale price method (RPM) — based on the markup applied on resale
- Cost plus method — based on the cost of production plus a normal profit
- Transactional net margin method (TNMM) — based on profitability indicators
- Profit split method — for integrated operations
What transfer pricing documentation includes
- A description of the group of companies and the interdependent parties
- An analysis of the functions, assets and risks of the parties to the transaction (FAR analysis)
- A description of each controlled transaction
- A justification of the chosen pricing method
- Financial calculations confirming that the prices conform to the market level
- Benchmarking — comparison with public data on comparable companies
Risks of having no documentation
If transfer pricing documentation has not been prepared, or has been prepared poorly, then during a tax audit the company may face:
- Additional assessment of profit tax on the difference between the actual and the "market" price
- Additional assessment of VAT on the portion of the amount not accounted for
- Penalties for violating transfer pricing rules
- Late-payment interest for the untimely payment of taxes
- The inability to defend itself without a documented, substantiated position
Common transfer pricing mistakes
- Using a single method for all transactions without justifying the choice
- Weak benchmarking — an insufficient number of comparable companies
- Ignoring differences in the functions and risks of the parties to the transaction
- Preparing documentation "after the fact" once a notice of audit has been received
- The absence of a coordinated transfer pricing policy at the group level
- Technical errors in the calculations and formulas
How to protect yourself against transfer pricing risks
- Implement a transfer pricing policy at the group level
- Prepare documentation in advance — before filing the tax return
- Update benchmarking regularly (at least once a year)
- Use specialized databases to find comparable companies
- Engage professional transfer pricing consultants
- Consider the possibility of an Advance Pricing Agreement (APA) with the tax authority
Conclusion
Transfer pricing is not a one-off exercise but an ongoing practice. High-quality transfer pricing documentation protects the company from substantial additional assessments during tax audits and makes it possible to use lawful opportunities to optimize intra-group transactions. If your company works with affiliated counterparties or has an international structure, it is worth conducting an audit of your current transfer pricing policy — Leader Audit will help with preparing the documentation and defending your position before the tax authorities.
Frequently asked questions
What qualifies as a controlled transaction in Uzbekistan?
Under the Tax Code of the Republic of Uzbekistan, controlled transactions include those between interdependent parties such as companies within the same group and affiliated parties, transactions with residents of countries on the blacklist of offshore jurisdictions, foreign-trade transactions in exchange-traded commodities such as oil, metals and agricultural products, and transactions exceeding the established turnover thresholds. Because the specific thresholds change over time, always check the version of the Tax Code currently in force.
What methods are used to determine the market price for transfer pricing?
The Tax Code of the Republic of Uzbekistan recognizes five methods, the same as those in the OECD standards: the comparable uncontrolled price method (CUP), the resale price method (RPM), the cost plus method, the transactional net margin method (TNMM), and the profit split method. The choice of method must be justified based on the functions, assets and risks of the parties, and applying a single method to all transactions without justification is a common mistake.
What are the risks of not preparing transfer pricing documentation?
If transfer pricing documentation is missing or poorly prepared, during a tax audit a company may face an additional assessment of profit tax on the difference between the actual and the market price, an additional VAT assessment on the unaccounted portion, penalties for violating transfer pricing rules, and late-payment interest. Without a documented, substantiated position, the company is largely unable to defend itself before the tax authorities.
When is transfer pricing documentation required in Uzbekistan?
Preparing transfer pricing documentation is mandatory for controlled transactions when the thresholds for the transaction amount and/or the company's overall turnover are exceeded. The specific thresholds change over time, so you should check the current values in the version of the Tax Code of the Republic of Uzbekistan now in force. Documentation should be prepared in advance, before filing the tax return, rather than after a notice of audit is received.
Related services: Tax consulting · Statutory audit
Read also: Uzbekistan Tax Code 2026: Key Changes Every Accountant and Owner Should Know
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