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STC publishes a project on taxation of non-residents and control in transfer pricing
The State Tax Committee of Uzbekistan has published a draft resolution of the Cabinet of Ministers of the Republic of Uzbekistan "On improving the administration of taxation of non-residents and tax control in transfer pricing."
- Provisions for notifying the tax authority of the payment of income to an alien;
- Provisions on the procedure for deducting administrative and general administrative expenses of a non-resident legal entity registered in the Republic of Uzbekistan as a permanent establishment;
- Provisions on the procedure for concluding a pricing agreement in respect of a foreign trade transaction, one of whose parties is a tax resident of a foreign state;
- Provisions on the procedure for filling out forms for notification of controlled transactions;
- Provisions on determining the grounds and procedure for extending the period for consideration of an application for concluding an agreement on pricing for tax purposes;
- Provisions on the determination of the grounds and procedure for extending the period for tax inspection in connection with the execution of controlled transactions;
- List of offshore jurisdictions.
The project was developed to ensure the comprehensive implementation of the provisions of the new edition of the Tax Code, as well as the creation of a system of effective tax administration of taxation of non-residents and tax control during transfer pricing.
In particular, the resolution approves the forms and procedure for notifying the tax authority of the payment of income to an alien.
The project provides for the introduction of a system for notifying taxpayers of tax authorities about transactions that are considered controlled in accordance with tax legislation.
The adoption of this resolution will order the rules for determining managerial and general administrative expenses of foreign legal entities operating through permanent establishments in the Republic of Uzbekistan.
The project approves a list of offshore jurisdictions with a view to applying transfer pricing, and tax administration of transactions between related parties and control over transfer pricing are also regulated.