The contemporary development of states in conditions of global competition for capital, financial technologies, cross-border services, and international arbitration flows drives the creation of special jurisdictional zones combining regulatory flexibility, a heightened level of legal predictability, and institutional autonomy. Global practice shows that international financial centers are formed not only as economic spaces, but also as special legal constructs in which the state allows a partial departure from the traditional model of the territorial application of national law in order to attract investors and transnational business.
Presidential Decree of the Republic of Uzbekistan No. PF-48 dated 30 March 2026 “On the Establishment of the Tashkent International Financial Center” represents one of the most ambitious regulatory steps in the legal and economic policy of Uzbekistan in recent years. The document directly links the establishment of the TIFC with the implementation of the “Uzbekistan – 2030” strategy, the increase in investment volume, the development of the capital market, the introduction of advanced international standards, and the transformation of Tashkent into an international financial hub. Thus, the establishment of the Center appears not as an isolated reform, but as an element of a broader model of economic modernization and the institutional positioning of Uzbekistan in the region.
Objectives of Establishing the TIFC
The Decree provides that the main objectives of its adoption are: ensuring additional GDP growth through the development of the financial sector; attracting long-term direct and portfolio foreign investment through the creation of a jurisdiction based on internationally recognized legal standards and a high level of trust; creating highly paid jobs in the fields of finance, law, and technology; strengthening the credit rating and investment attractiveness of Uzbekistan; transforming the country into a regional financial center and integrating it into the global financial system.
Several fundamental conclusions follow from this list of objectives.
First, in this case the legislator views the financial center not as a local zone servicing capital, but as a systemic driver of economic growth. This means that the effectiveness of the TIFC should be assessed not only by the number of residents or the volume of investment, but also by its multiplier effect on the banking sector, the stock market, legal and consulting services, as well as human capital.
Second, the Decree expressly emphasizes the importance of “internationally recognized legal standards” and a “high level of trust.” In doing so, the state effectively acknowledges that for international capital, material incentives alone are insufficient; the key factor is trust in the rules, procedures, courts, and stability of the regime. Consequently, the TIFC is conceived primarily as a jurisdiction of trust.
Third, the expected result is defined not only as an inflow of investment, but also as an improvement in international rankings. This gives the Center a reputational function: it is expected to become a showcase of Uzbekistan’s institutional reforms and a mechanism for integrating the national economy into international financial chains.
Institutional Model of the Center
The Decree approves the proposal to establish: 1) the Tashkent International Financial Center; 2) the Tashkent International Commercial Court within the Center. At the same time, it defines a broad range of permissible activities within the Center: financial, investment and banking activities, insurance, digital (crypto) assets, securities, payment systems and services, Islamic and green finance, fintech, auditing, consulting and legal services, as well as other activities to be provided for by the future constitutional law on the Center.
Such regulation allows the TIFC to be characterized as a comprehensive legal cluster. Its purpose is not only to service financial transactions, but also to form a supporting professional ecosystem. The presence within one space of a regulator, a court, professional consultants, audit structures, law firms, fintech companies, and providers of payment infrastructure corresponds to the logic of leading international financial centers.
Main Tasks of the TIFC
The tasks of the TIFC are formulated in four areas: attracting investment; developing and integrating the capital market; modernizing the financial sector; and forming an innovative ecosystem of financial and professional services.
Legally significant is the fact that the Center is conceived not only as a mechanism for admitting foreign financial institutions, but also as a space for the institutional upgrade of the national system. Thus, the task of developing the capital market and integrating it with international markets means that the TIFC is expected to serve as a channel for the standardization of financial regulation, corporate governance, disclosure, and the circulation of capital market instruments.
Equally important is the task of creating an innovative and professional ecosystem. This indicates the state’s understanding that a modern financial center is not merely a tax haven and not merely a place for company registration, but an environment in which legal, compliance, technological, and consulting services become an independent part of economic value.
Special Legal Regime
The most significant part of the Decree is the introduction of a special legal regime within the Center, which is to be established by a constitutional law. Already at the Decree level, it is provided that the governing bodies of the Center are granted the right to adopt regulatory legal acts applicable within the territory of the Center on issues of civil, corporate, commercial, financial, banking, tax law, public procurement, labor law, and personal data protection.
The Center is vested with delegated sectoral regulatory competence. The legal nature of such competence requires further clarification in the future constitutional law: it is necessary to define the hierarchy of the Center’s acts, the limits of their application, the order of conflict-of-law correlation with nationwide legislation, and the mechanism of judicial review.
From the standpoint of legal theory, this model represents a form of limited normative pluralism. Within the territory of one state, a special legal space is formed in which an independent regulatory body of law operates, oriented toward a separate category of subjects and transactions. Similar constructions are known in foreign practice; however, for the national legal system of Uzbekistan this is a highly significant innovation.
It is particularly important that the subjects of special regulation include not only corporate and financial law, which is logical for an international financial center, but also labor relations, public procurement, and personal data protection. This indicates an intention to create for the Center’s participants a comprehensive rather than fragmented model of autonomous regulation.
Direct Application of the Common Law of England and Wales
The boldest provision of the Decree is that within the territory of the Center, the common law of England and Wales and the principles of equity shall apply directly, unless otherwise provided by the constitutional law on the Center and by the regulatory legal acts of the Center itself. In addition, the Center is authorized to determine the direct application within its territory of advanced practices, principles, standards, and rules of other international financial centers.
This provision is of fundamental significance.
First, the Decree effectively establishes a mechanism for the direct adoption of a foreign legal tradition within a specially designated jurisdiction. Unlike ordinary comparative legal borrowing, where individual institutions are incorporated into national legislation, here a space is created in which a foreign legal system acquires immediate practical effect.
Second, the choice of the common law of England and Wales is understandable from the perspective of international commercial practice. This system is highly predictable in the field of contract law, corporate relations, fiduciary duties, security for obligations, judicial remedies, and the interpretation of commercial transactions. For foreign investors, this reduces transaction costs and increases trust in the jurisdiction.
Third, the direct application of common law inevitably raises questions regarding the methodology of its implementation: which sources should be taken into account; what is the role of judicial precedents; how translation and authentic interpretation will be ensured; and how common law principles will be reconciled with the mandatory public policy norms of Uzbekistan. These issues have not yet been conclusively resolved at the regulatory level; however, the practical viability of the entire model will depend precisely on the answers to them.
Thus, the TIFC may become a platform for institutional legal “bilingualism,” where the national legal order and the Anglo-Saxon legal tradition will coexist within an established sphere of application.
Legal Status of the Center’s Participants and Investment Guarantees
The Decree establishes a number of substantial rights for the Center’s participants and their employees. In particular, the performance of monetary obligations in foreign currency, including crypto-assets, is permitted; the employment of foreign nationals without obtaining confirmation of the right to engage in labor activity is allowed; special entry visas valid for up to five years are provided for employees of the Center’s bodies, participants, and their family members; and the unhindered repatriation of capital and income derived from activities within the territory of the Center is guaranteed.
This set of legal preferences reflects the classic features of an internationally competitive financial jurisdiction.
The performance of obligations in foreign currency and crypto-assets means a reduction in regulatory barriers for international transactions and recognition of the nature of a financial center as a space for cross-border turnover. The possibility of hiring foreign employees without the standard permit regime is aimed at the rapid concentration of international expertise in finance, law, and technology. The special visa regime strengthens labor mobility and makes the Center more convenient for foreign professionals and investors. Finally, the unhindered repatriation of capital eliminates one of the key fears of external investors — the risk of restrictions on profit repatriation.
Taken together, these provisions indicate that the Decree seeks to form not merely a preferential business regime, but a full-fledged investment guarantee environment based on the principles of capital mobility, openness to talent, and currency flexibility.
Tashkent International Commercial Court
The Decree determines that the Tashkent International Commercial Court consists of a court of first instance and a court of appeal. Its jurisdiction covers: disputes related to the activities of the Center and the International Digital Technology Center; disputes arising from contracts in which the parties have chosen the jurisdiction of this court; administrative disputes where one of the parties is a foreign enterprise, an enterprise with foreign investment participation, or a foreign investor who is an individual; certain administrative-law disputes at the option of the entrepreneur; as well as issues related to international arbitration where the place of arbitration is located in the territory of Uzbekistan. The decisions of the court are binding and enforced in the manner established for the acts of courts within the system of the Republic of Uzbekistan.
This approach merits separate analysis.
First, the court is embedded in the model of the Center as a mandatory institution of trust. For international business, the existence of a specialized court is often more important than fiscal benefits, since it is judicial predictability that determines the cost of risk in a transaction.
Second, the court’s jurisdiction is formulated rather broadly. It includes both corporate-contractual disputes and certain administrative and arbitration-related disputes. This expands its importance from that of a narrowly specialized commercial court to an element of investment and judicial infrastructure.
Third, important is the provision on the binding force of its decisions and their enforcement in the general manner provided for judicial acts of Uzbekistan. Thus, a bridge is created between the autonomous jurisdiction of the Center and the state enforcement system. It is precisely this that prevents the court from becoming a purely symbolic institution and makes its decisions practically significant.
At the same time, further regulatory detail should answer a number of questions: the language of the proceedings; the status of judges; procedural standards of proof; the applicable law in mixed disputes; the relationship with the state courts of Uzbekistan; the limits of review and the grounds for refusal of enforcement. Without such detail, the high potential of the institution may remain limited.
Tax Regime
The Decree provides for the application of tax benefits within the territory of the Center until 1 January 2076. In addition, taxation matters between the tax authorities and the Center, including its participants, are subject to regulation by the Center’s documents.
The very fact that a preferential regime is established until 2076 is of particular significance. This is not a short-term investment incentive, but an ultra-long-term horizon of regulatory stability. For international investors, the duration of the regime is no less important than the amount of the benefits: it allows them to build capital investment models, structure funds, open regional headquarters, and calculate the payback period of long-term projects.
From the standpoint of legal drafting, it is also notable that taxation matters in relations between the Center and the tax authorities are transferred to special regulation by the Center’s documents. This may imply the formation of an autonomous tax-administrative practice within the special jurisdiction, which strengthens the institutional independence of the TIFC.
Benefits and Preferences of the Tashkent International Financial Center
|
No. |
Benefit / Preference |
Applicable to |
Term |
Limitation / Condition |
Practical Comment for Investor |
|
1 |
Exemption from corporate income tax |
The Center’s bodies and participants of the Center |
Until 1 January 2076 |
The benefit applies to income from services rendered within the territory of the Center; digital (crypto) exchanges are expressly excluded from the text |
This is one of the key tax benefits. For service, financial, legal, consulting, and other residents of the Center, it reduces the cost of doing business and increases structural profitability. |
|
2 |
Exemption from social tax |
The Center’s bodies and participants of the Center |
Until 1 January 2076 |
Applies to income from services within the territory of the Center; digital (crypto) exchanges are also excluded |
Significantly reduces the fiscal burden on payroll and service activities. Especially important for companies with a high share of personnel: fintech, compliance, legal, and consulting firms. |
|
3 |
Exemption from personal income tax on foreigners’ salaries |
Foreign citizens and stateless persons to whom the Center’s bodies or participants pay salaries in connection with activities in the Center |
Until 1 January 2076 |
The benefit concerns specifically employment income within the framework of activities in the Center |
This is a strong tool for attracting foreign specialists. It makes it possible to build international teams at lower cost and compete for talent with other financial jurisdictions. |
|
4 |
Exemption from corporate property tax |
The Center’s bodies |
Until 1 January 2076 |
The benefit applies to objects located at the disposal or use of the Center’s bodies within the territory of the Center |
This is primarily an infrastructural benefit. It is important first of all for the institutional platform of the Center itself, but it is also indirectly beneficial for participants, as it reduces the cost of operating the basic infrastructure. |
|
5 |
Exemption from land tax for legal entities |
The Center’s bodies |
Until 1 January 2076 |
Only in respect of property/land at the disposal or use of the Center’s bodies within the territory of the Center |
This is also an infrastructural benefit. The direct beneficiary is the Center itself, but the economic effect may be passed on to participants through a more favorable placement model. |
|
6 |
Application of tax benefits until 2076 |
Participants and the Center’s bodies to the extent provided in the Decree |
Until 1 January 2076 |
It should be taken into account that the full scope of tax consequences will also depend on further acts of the Center |
The long horizon is one of the strongest factors of investment predictability. For funds, holdings, and regional headquarters, this is more important than a one-time benefit. |
|
7 |
Right to perform obligations in foreign currency |
Participants of the Center and their counterparties |
No separate time limit expressly established; applies within the special regime |
The currency must be provided for in the contract |
For cross-border transactions this is critically important: it removes many local currency risk restrictions and simplifies financing, loans, fee arrangements, and investment structures. |
|
8 |
Right to perform obligations in crypto-assets |
Participants of the Center and their counterparties |
Within the special regime |
Must be provided for in the contract; practical implementation will depend on the Center’s regulatory rules |
This is a strong preference for digital assets, Web3, crypto-services, and tokenized products. In practice, however, secondary regulation will need to be reviewed carefully. |
|
9 |
Employment of foreign citizens without confirmation of the right to labor activity |
Participants of the Center |
Within the special regime |
Applies to the hiring of foreigners within the framework of the Center’s regime |
For international business, this is one of the most valuable administrative benefits. It reduces office launch time and lowers bureaucratic barriers for team relocation. |
|
10 |
Special visa for up to 5 years |
Employees of the Center’s bodies, employees of participants of the Center, and members of their families |
Up to 5 years |
The procedure must be determined by the Center in coordination with authorized state bodies |
This is a powerful factor for relocation strategy. It is particularly important for international banks, fintech companies, law firms, and consultants relocating senior staff. |
|
11 |
Free repatriation of capital and income |
Participants of the Center |
Within the special regime |
Applies to capital or income received from activities within the territory of the Center |
For a foreign investor, this is a basic guarantee for exit and dividend policy. Without such a guarantee, even tax benefits often do not work to their full extent. |
|
12 |
Special tax administration |
The Center, its bodies, and participants |
Within the special regime |
Taxation matters between the tax authorities and the Center are regulated by the Center’s documents |
This is not a separate tax benefit, but a very important procedural preference. It may reduce uncertainty in disputes over the tax regime if the Center’s documents are clear. |
|
13 |
Direct application of the common law of England and Wales |
Participants of the Center, their counterparties, and disputes within the scope of the regime |
Within the special regime |
Otherwise may be established by the constitutional law on the Center and its regulations |
This is not a fiscal but a legal super-preference. For investors, a familiar legal environment is often more valuable than a tax benefit, because it affects enforceability, M&A deals, shareholder agreements, and financing documents. |
|
14 |
Application of the principles of equity |
The same subjects operating within the Center’s regime |
Within the special regime |
Will depend on how these principles are developed in future acts and judicial practice |
This strengthens the toolkit for the protection of rights, especially in contractual, corporate, and fiduciary relationships. In practice, it is important for investors in complex joint ventures and investment structures. |
|
15 |
Possibility of direct implementation of best practices of other international financial centers |
The Center and participants of the Center |
Within the special regime |
Formalization through acts of the Center will be required |
This gives the regime flexibility and a chance to quickly adopt the standards of the AIFC, DIFC, ADGM, and other centers without completely restructuring national legislation. |
|
16 |
Recognition of residents and licenses of foreign financial centers, mechanism of dual residency, exchange of information |
Participants of the Center and foreign financial institutions |
Within the special regime |
Agreements and specific procedures will be required |
For investors, this may potentially mean easier market entry and lower regulatory barriers in cross-border activities. But for now this is a framework norm rather than an automatically applicable benefit. |
|
17 |
Specialized international commercial court |
Participants of the Center and other persons whose disputes fall under its jurisdiction |
Permanent element of the Center’s model |
Rules of jurisdiction and the choice of this jurisdiction in contracts are important |
For investors, this is one of the main institutional guarantees. The possibility to designate such court in contracts in advance increases confidence in the transaction and reduces litigation risk. |
|
18 |
Enforceability of decisions of the international commercial court in the general manner of the court system of Uzbekistan |
Parties to disputes before this court |
Permanent |
Further detailing of the procedural mechanism is required |
This is an extremely important element: the existence of a court is useful only when its decisions are actually enforceable. The Decree expressly provides for such enforceability. |
|
19 |
Broad range of permitted activities in the Center |
Financial, investment, banking, insurance, fintech, crypto, payment, Islamic and green finance entities, as well as audit, consulting, and law firms |
Permanent, within the Center’s model |
Activities must comply with the Center’s regime and the future constitutional law |
This is not a benefit in the narrow sense, but a regulatory window. It makes it possible to build a full ecosystem play in one jurisdiction: licensed business + consultants + financing + judicial protection. |
|
20 |
Special regime for lease and sublease of premises |
The Center’s bodies and its participants |
Within the Center’s regime |
Premises are first leased to the Center’s bodies and then subleased to participants |
This facilitates the rapid physical setup of business within the territory of the Center and makes entry into the regime more convenient. |
|
21 |
Simplified procurement of expert, legal, and analytical services for launching the regime |
Bodies establishing the Center |
Until 1 January 2027 |
This is not a benefit directly for investors, but for launching the regime itself |
For the market, this means accelerated formation of the Center’s legal architecture. The indirect benefit for investors is a faster launch of a fully functioning jurisdiction. |
|
22 |
State financing of the Center’s launch |
The Center itself as an institution |
For 2026, USD 20 million is expressly provided |
This is not a private benefit for participants, but initial institutional support |
For investors, this signals the seriousness of the project: the state finances the launch of infrastructure, the court, and regulation, rather than merely declaring the regime on paper. |