Tax Audits in Uzbekistan

As in all countries, tax audits in Uzbekistan are conducted to monitor compliance with tax legislation by taxpayers, fee payers, and tax agents. Such audits are carried out based on the study and analysis of data on the taxpayer available to the tax authorities of Uzbekistan.

Tax audits are not conducted for business entities with an "AAA" rating under the business stability rating system. However, tax audits may be conducted without any restrictions:

• for any business entities in connection with criminal cases (including those with an "AAA" stability rating);
• for any state-owned enterprises and legal entities with a state share of 50% or more in the authorized capital.

Tax audits are divided into three types: desk tax audit, field tax audit, and tax audit (audit inspection).

Desk Tax Audit

A desk tax audit is an audit conducted based on the study and analysis of the taxpayer's submitted tax reports and/or other information on their activities available to the tax authority, in order to verify the correctness of tax calculation, timeliness, and completeness of payment of taxes and fees to the budget.

Field Tax Audit

A field tax audit is an audit of taxpayers' compliance with obligations related to tax calculation and payment, as well as other duties provided by tax legislation. It involves the analysis of accounting records, movement of goods and materials, cash flows, and other information related to the taxpayer's activities.

Tax Audit (Audit Inspection)

A tax audit is the verification of the accuracy of the taxpayer’s calculation and payment of taxes for a specific period by reviewing financial and tax reports for accuracy and compliance with tax legislation, as well as the correctness of the formation and reflection of tax obligations in accounting and tax records.

Field tax audits and tax audits of legal entities are conducted by tax authorities with mandatory prior notification of the Business Ombudsman – the Commissioner under the President of the Republic of Uzbekistan for the Protection of the Rights and Legitimate Interests of Business Entities.

Differences Between Types of Tax Audits

Criterion	Desk Tax Audit	Field Tax Audit	Tax Audit
Procedure	Remotely – by analyzing tax reports, financial statements, and other documents and information.	On-site at the taxpayer's location.	On-site at the taxpayer's location. If not possible, documents are submitted to the tax authority.
Category of Taxpayers Checked	Only taxpayers with a high-risk category.	All taxpayers if grounds exist.	All taxpayers if grounds exist.
Initiating Document	Order of the head (or deputy) of the tax authority (except for VAT refund audits, where no order is required).	Order of the head (or deputy) of the tax authority.	Order of the head (or deputy) of the tax authority based on an audit program.
Notification	Not required.	Not required.	Written notice 30 calendar days before the audit (except certain cases).
Grounds for Audit	Non-submission of updated tax reports within 10 days, detected errors, high-risk indicators, appeals from individuals/legal entities, VAT refund request, etc.	Risk indicators, complaints, media reports, need for additional information, etc.	Failure to correct discrepancies after desk audit, liquidation of legal entities, termination of entrepreneurs, completion of activities by foreign permanent establishments, etc.
Audit Period	Up to last 3 years.	Up to last 3 years.	Up to last 3 years (not affecting previous audit period).
Audit Duration	≤ 60 days (30 days for VAT refund audit).	≤ 10 days.	≤ 30 working days (can be extended to max. 6 months).
Final Document	Conclusion on discrepancies or absence thereof; Act of tax violation if applicable.	Field tax audit report; Act of tax violation if applicable.	Tax audit report; Act of tax violation if applicable.
Taxpayer Actions	Submit updated tax reports or justifications within 5 days.	May submit objections within 10 days.	May submit objections within 10 days.
Final Decision	Decision on additional tax charges/penalties or refusal thereof (effective 1 month after delivery).	Same as for desk audit.	Same as for desk audit.
Appeal	May be appealed to higher tax authority or court within 30 days.	Same.	Same.

 

Taxpayer Rights During Audits

Taxpayers have the right to:

• Refuse to comply with tax officials’ demands unrelated to the audit.
• Participate personally or through a representative (lawyer, tax consultant, etc.) during the audit.
• Submit explanations to tax authorities regarding compliance with tax legislation.
• Refuse to submit documents already provided during previous audits or tax monitoring.
• Challenge the appointment of an expert and request an expert of their choosing.
• Attend expert examinations, provide explanations, and review the expert’s report.
• Review the audit materials and receive a copy of the audit report.
• Appeal unlawful actions of tax officials.
• Submit reports or opinions from tax consulting organizations as evidence during or after the audit.

During field audits or tax audits, taxpayers may deny entry to tax officials if:

• The audit order is not properly issued or a copy was not provided;
• The auditor is not listed in the order or has not presented an ID;
• The audit period specified in the order has not started or has expired.

Appeal of Tax Authority Decisions

Decisions of the tax authority may be appealed to a higher tax authority or to the court.

• Economic and civil courts handle disputes over tax debt recovery, return of taxpayer funds from the budget, and application of legal enforcement measures.
• Administrative courts handle appeals of tax authority decisions, actions (or inaction) of tax officials, and refusals to register consolidated taxpayer groups.

Filing an appeal suspends the execution of the contested decision or action (including tax collection and penalties) until a higher authority or court decision enters into force. Taxpayers must notify the tax authority in writing and attach a copy of the appeal.