Transfer Pricing Documentation

Who It's For

• Multinational groups with Uzbek subsidiaries or branches transacting with related entities
• Companies with intercompany loans, royalties, management fees, or service arrangements
• Tax directors and CFOs managing cross-border compliance across Central Asian operations
• Private equity and M&A teams preparing a Uzbek entity for sale or restructuring

Why You Need It

Uzbekistan's tax code requires companies to document related-party transactions that exceed statutory thresholds, following OECD transfer pricing methodology. Without a master file and local file, the State Tax Committee has the authority to re-price any intercompany transaction using its own comparables — which almost always results in a higher taxable income and a surcharge. Beyond the direct tax adjustment, the penalties for undocumented transactions are applied on top of any tax reassessment. This pack provides both the master file and local file in the OECD-recommended format, a benchmarking guide for identifying comparable transactions, and a policy statement that can be updated annually.

Risks Without It

• The tax authority re-prices intercompany transactions unilaterally, potentially adding 20–40% to the effective tax rate
• Separate penalties for failing to maintain transfer pricing documentation, applied on top of any tax adjustment
• Tax reassessment for multiple prior years if documentation cannot be produced during an audit
• Investors and acquirers treat undocumented TP exposure as a material deal risk, reducing valuation
• Management fees and royalties paid to foreign related parties are entirely disallowed without proper documentation