Special Tax Regime for Foreign Individuals in Uzbekistan: A New Model of Tax Residency

Introduction

As of 1 January 2026, the Republic of Uzbekistan has introduced a special tax regime for foreign individuals under Presidential Decree No. UP-180 dated 4 October 2025.

This mechanism represents a fundamentally new tool for attracting international capital and is primarily aimed at high-net-worth individuals, entrepreneurs, and persons deriving the majority of their income outside Uzbekistan.

Unlike traditional models based on prolonged physical presence or substantial investment thresholds, the Uzbek approach establishes a flexible framework allowing individuals to obtain tax residency on preferential terms.

 Legal Nature of the Regime

The core feature of the regime is the possibility for a foreign individual to be recognized as a tax resident of Uzbekistan under special conditions, deviating from the standard requirement of spending more than 183 days per year in the country.

A key element is the tax preference whereby foreign individuals are exempt from personal income tax on income earned outside Uzbekistan.

In effect, this creates a model closely aligned with the territorial principle of taxation, making the jurisdiction particularly attractive for individuals with globally diversified income streams.

 Eligibility Criteria

To obtain tax residency under the preferential regime, a foreign individual must meet several statutory requirements:

• One-time contribution: USD 50,000 paid to the state budget;
• Financial integration: opening a bank account in an authorized Uzbek commercial bank or a crypto wallet on a registered platform;
• Physical presence: at least 30 calendar days in Uzbekistan within any consecutive 12-month period;
• Residential requirement: ownership or lease of residential property in Uzbekistan.

These conditions significantly lower traditional entry barriers and accommodate individuals with high international mobility.

 No Mandatory Real Estate Investment

One of the most distinctive features of the regime is that the residential requirement may be satisfied through leased property.

Unlike many comparable programs globally, where real estate acquisition is mandatory, the Uzbek model allows participation without capital immobilization.

This substantially reduces the financial burden and preserves liquidity for investors.

 Extension to Family Members

The regime may also be extended to close family members.

Upon payment of an additional fee of USD 10,000 per adult family member, such individuals may obtain the same tax status.

This enables structuring tax residency at the family level and supports broader wealth and succession planning strategies.

 Economic Significance

The introduction of this regime reflects Uzbekistan’s strategic policy to attract high-value foreign individuals.

It is particularly relevant for:

• international entrepreneurs and business owners;
• global investors;
• participants in the digital economy, including so-called digital nomads.

An additional effect is the strengthening of the national financial ecosystem through increased participation in banking and crypto sectors.

 International Considerations and Risks

Despite its advantages, the regime requires careful assessment of international tax implications.

A key factor remains the concept of the “centre of vital interests”, widely used in international tax practice. Recognition as a tax resident in Uzbekistan does not automatically terminate tax obligations in other jurisdictions.

Particular attention should be paid to:

• double taxation treaties;
• domestic tax laws of jurisdictions where income is generated.

 Practical Considerations

For effective implementation, a prior legal and tax assessment is strongly recommended.

Key compliance aspects include:

• tracking physical presence;
• proper documentation of ownership or lease agreements;
• obtaining an official tax residency certificate.

Failure to comply with formal requirements may result in denial of status or loss of tax benefits.

 Conclusion

The special tax regime introduced by Decree No. UP-180 establishes a modern and competitive model of tax residency in Uzbekistan.

The combination of minimal physical presence, a fixed contribution, and exemption from taxation on foreign income positions this regime as an effective tax planning инструмент for internationally mobile individuals.

The ability to rely on leased residential property further broadens accessibility and enhances Uzbekistan’s competitiveness in attracting global investors and professionals.