Commercial invoice and tax invoice: how they differ and when each is needed

In brief: the main differences

• Purpose. A commercial invoice evidences a foreign trade transaction and the value of the goods for customs and the bank. A tax invoice (ESF) is a tax document recording a sale within Uzbekistan's tax system.
• Legal basis. The commercial invoice — the Customs Code (Article 9, commercial documents). The tax invoice — the Tax Code (Article 47); its form and completion procedure are approved by the Cabinet of Ministers.
• Form. There is no single state form for a commercial invoice; it is drawn up in line with the contract, often in English. An ESF is issued in the electronic invoice information system in the approved form.
• Recipient. A commercial invoice is issued to a foreign counterparty. An ESF — to a buyer that is a taxpayer in Uzbekistan.
• Tax consequences. On the basis of an ESF, the buyer offsets VAT. A commercial invoice by itself gives no right of offset; on import, VAT is paid at customs.

What a commercial invoice is and what types exist

In business practice, a distinction is made between a commercial invoice — the final shipping document with price, quantity, delivery terms and the parties' details — and a proforma invoice: a preliminary invoice used to agree terms, request prepayment or open a letter of credit. For customs and the bank, what matters is the commercial invoice consistent with the contract.

The Customs Code classifies as commercial documents the invoice, shipping documents and packing lists and other documents confirming transactions involving the movement of goods across the customs border (Article 9). In international road transport, when goods are imported the carrier must submit commercial documents, among others, to the customs authority; the documents must state the name and codes of the goods under the Harmonised System to at least six digits, the gross weight and the invoice value of the goods for each code.

What a tax invoice under the Tax Code is

When selling goods (services), legal entities, individual entrepreneurs and self-employed persons must issue tax invoices to buyers (Article 47(1) of the Tax Code as in force from 1 January 2026). As a rule, the tax invoice is issued electronically in the electronic invoice information system.

A tax invoice need not be issued if the seller has given the buyer a cash register receipt or another document of the prescribed form. When the value, price or quantity changes, the seller must issue an additional or corrected tax invoice. The form of the tax invoice and the completion procedure are approved by the Cabinet of Ministers (Article 47 of the Tax Code). Each line of an ESF shows the product identification code (IKPU) from the national catalogue.

Exports: an invoice for the buyer and customs, 0% VAT rate

For exports, the foreign buyer and customs need a commercial invoice under the contract. To apply the zero VAT rate (Article 258 of the Tax Code), the export is confirmed by the documents listed in Article 261 of the Tax Code:

• the contract (a copy certified in the established manner);
• the export cargo customs declaration — or documents for the export of goods sold through national and foreign e-commerce platforms;
• transport documents bearing the mark of the customs authority at the border crossing point confirming that the border was crossed.

How the documents connect in exports

Since 2025, information on border crossing that customs transmits to the tax authorities electronically in real time also serves as grounds for confirming exports (Article 261(2) of the Tax Code). When exporting through a commission agent, the commission or agency agreement is also submitted. Depending on the type of activity, other documents may be required as well: their list is approved by the Cabinet of Ministers.

A practical rule: the data in the invoice, the cargo customs declaration and the books must match — description, quantity, price, currency, contract number and date. Discrepancies are a frequent cause of questions when confirming the zero rate and claiming VAT refunds.

Imports: an invoice from the supplier, VAT at customs

For imports, the commercial invoice is issued by the foreign supplier and forms part of the set of commercial documents for customs clearance (Article 9 of the Customs Code). The VAT rate is 12% (Article 258 of the Tax Code); the tax base on import is determined under Article 254 of the Tax Code, and the tax is paid during customs clearance, not on the basis of the supplier's invoice.

When you then sell the imported goods in Uzbekistan, the buyer receives a regular ESF with IKPU codes — the supplier's invoice does not replace it.

Common errors

• Confusing a proforma with a commercial invoice: customs needs an invoice consistent with the contract and the actual shipment.
• Issuing an Uzbek buyer an «invoice» instead of an ESF: this does not remove the obligation to issue a tax invoice under Article 47 of the Tax Code.
• Discrepancies between the invoice, the contract and the declaration in description, price or quantity.
• Failing to issue an additional or corrected ESF when the price or quantity changes (Article 47 of the Tax Code).