Tax ·
Transfer pricing in Uzbekistan: controlled transactions, notification and documentation
What to check under Articles 180–182 and 193 of the Tax Code.
Dilora Saydamenova · Director
Controlled transactions and related parties
Articles 180–182 of the Tax Code define related parties and controlled transactions. Start with the group structure, relationships between the parties and the terms of each transaction. The presence of a foreign counterparty does not replace an assessment of the applicable criteria.
Notification
After identifying controlled transactions, prepare the notification. Its information should be consistent with the agreements, accounting records and transfer pricing documentation.
Documentation
Under Article 193, documentation must be submitted within 30 calendar days of a tax authority request. It contains a description of the group and transactions, functional analysis of functions, assets and risks, the selected method, comparables and a conclusion.
Practical steps
Collect intercompany agreements and evidence of performance early, maintain the database of comparables and reconcile actual transactions with the records. Deadlines and forms depend on the current edition of the Tax Code — we check them for each engagement.
