Tax Risk Rating of Companies in Uzbekistan: How It Works

What tax risk and the degree of tax risk mean

The Regulation gives precise definitions. Tax risk is the likelihood that a taxpayer (tax agent) will not fulfil, or will not fully fulfil, its tax obligations, so that taxes are not received or are not received in full by the budget. The degree of tax risk is the state of that risk, determined by the likelihood of it occurring and its possible consequences.

The Regulation states the aims of the system directly: to focus attention on high-risk areas and to minimise tax control over taxpayers whose risk is assessed as low. Selection for tax inspections is to be automated, without the human factor, and the form of inspection is chosen according to the degree of risk.

The strategy of the system, the collection and processing of information and the analysis and assessment of risks are determined by the Tax Committee (clause 4 of the Regulation).

Where the tax authority gets data about a company

Risk is analysed using data from many sources (clause 7 of the Regulation). This is why the software sees any mismatch between your reporting and the data of other authorities or counterparties without any inspection.

• tax and financial statements filed by the company itself and the data in its personal account card;
• information passed to the tax authority by state bodies and organisations;
• information from competent authorities of foreign states under exchange agreements;
• materials of earlier tax inspections;
• decisions of courts and law-enforcement bodies on tax offences;
• complaints from individuals and legal entities about tax violations, statistics data and media reports;
• data on breaches of the mandatory digital labelling rules.

Tax risk criteria

The specific criteria are set by the Tax Committee, and their list is published openly on its official website (clause 17 of the Regulation). Clause 9 of the Regulation lists what must be taken into account:

• tax burden — the ratio of taxes to revenue, compared with the average for the type of activity (the Tax Committee publishes the averages on its website every year);
• repeated corrections of previously filed reports — three or more times for the same reporting period;
• losses in the statements for several (two or more) tax periods;
• changing location two or more times within a tax period followed by re-registration;
• transactions with persons whose VAT payer certificate has been cancelled, as well as with liquidated, dormant or bankrupt entities;
• low profitability (the ratio of net profit to expenses);
• a mismatch between the VAT return and the counterparty's data on the same transactions;
• filing reports with turnover below one billion soums for several years in a row, which gives the right to special tax regimes;
• the results of tax inspections already carried out.

How the risk level is calculated

Each criterion is assigned from 1 to 100 points; the distribution of points depends on the company's segment by type of activity and on its income for the tax period (clause 11 of the Regulation). The degree of risk is then calculated using the formula R = Sr / Sp × 100%, where Sr is the sum of points assigned to the taxpayer and Sp is the sum of points of potential tax risk (clause 13).

The percentage is converted into a category: 81 to 100% is high risk, 30 to 80% is medium, and 1 to 29% is low. Construction companies are subject to additional criteria (clause 10): a shortage of workers, warehouses, transport and machinery for the declared works, the absence of necessary expenses in the statements, interdependence of contractors on one site, large sums arriving on the account of a recently created company, and the sale of finished properties at a price close to cost.

How often the risk is reviewed and how to find out your category

The degree of risk is determined once every six months (clause 15). If a taxpayer whose risk is not high has a tax debt that remains unpaid for more than thirty calendar days, its risk is recalculated every quarter (clause 16).

Chapter 5 of the Regulation on informing taxpayers comes down to two things: the list of criteria is published openly, and communication with the tax authority about them goes through the taxpayer's personal account. Through it, a company may send explanations on the risk criteria (clause 18), and these explanations may be taken into account when the risk is adjusted (clause 19). It is also established that the opinion of a tax consultant issued as part of tax accounting services is accepted by the tax authorities when assessing tax risk (clause 19¹).

What the risk level affects

The main consequence is a tax audit. It is ordered for high-risk companies (clause 14 of the Regulation, Article 140 of the Tax Code); other tax administration measures under the Tax Code apply to medium and low risk. The tax authority gives notice of a tax audit at least thirty calendar days before it starts, but where there are signs of tax evasion it may begin the audit without notice (Article 140 of the Tax Code). How the inspections themselves are conducted is covered in our article on tax inspections.

A similar logic applies to invoices: an e-invoice may be classed as high tax risk, and the buyer can then offset VAT on it only under the special procedure of Article 266¹ of the Tax Code — by paying the tax as a tax agent. More on this in our material on electronic invoices.

Low risk will also bring a VAT advantage: Presidential Decree No. UP-95 of 19.05.2026 provides that from 1 January 2027, for low-risk taxpayers, the negative VAT difference arising from the zero rate and from the purchase of real estate will be covered (refunded) automatically within three days; the current procedure is kept for certain categories.

The sustainability rating: the “AAA” category

The “tax discipline rating” people often ask about is called in the Tax Code the business sustainability rating. It identifies and rewards entrepreneurs who operate in compliance with the law, under a procedure approved by the Cabinet of Ministers (Article 60 of the Tax Code). It is not the same as the degree of tax risk, but it rests on the same discipline.

What a high rating gives under the Tax Code (except for state enterprises and companies with a state share of 50% or more):

• “AAA” category: no tax inspections are carried out, except inspections within criminal cases (Article 137 of the Tax Code);
• “AAA” category: an accelerated procedure for refunding the full amount of VAT (Article 274 of the Tax Code);
• high rating: overpaid tax (other than VAT) is refunded within three days instead of fifteen, and the refund decision is taken within two days instead of ten (Article 104 of the Tax Code).

How to lower your tax risk: a practical checklist

Points can only be influenced through the criteria themselves, so it helps to go through them regularly as a checklist:

• compare your tax burden with the average for your type of activity and prepare an explanation in advance if it is lower;
• file reports correctly the first time, so that you do not correct the same period three or more times;
• reconcile VAT data with counterparties before filing the return;
• check suppliers: whether their VAT payer certificate is valid, whether they have been liquidated and whether they are actually operating;
• do not let a tax debt run for more than 30 days — otherwise your risk will be recalculated every quarter;
• if you have losses over several years or low profitability, send explanations through the personal account;
• obtain a tax consultant's opinion on disputed tax accounting issues.