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Personal Income tax 1.1 1.5 1.3 1.8 11.4 145.3

Grants from Union Budget 2.3 3.6 6.4 11.4 0.0 0.0

Expenditure 10.1 11.0 14.9 32.4 193.9 1,923.4

of which:

Economy 4.6 5.0 8.1 5.9 20.9 392.7

Defense and Public Order n/a n/a n/a 0.2 11.7 n/a

Social and Cultural 5.2 5.5 6.2 9.2 70.8 n/a

Balance -0.4 -0.8 -0.2 -2.4 -54.1 -108.9

% of GDP -1.4 -1.0 -1.2 -3.6 -12.1 -2.5

* 1993 data are from the World Bank. They exclude non-budgetary accounts.

Sources: IMF, Economic Review: Uzbekistan; World Bank, Statistical Handbook: States of the Former USSR, 1994

IV. Tax Structure and Administration¹²

Corporate Taxation

Profit Tax

Uzbek entities ‑ taxed on their profits from all sources worldwide.

Foreign Entities ‑ taxed on profits from the entrepreneurial activities of their establishments in Uzbekistan.

Foreign entities receiving income from Uzbek sources other than through Permanent Establishments are subject to withholding tax on the gross amounts of the income without reduction for any expenses.

The general profit tax rate is 37%. This rate is reduced to 25% for entities with foreign investment of 30% or greater.

A tax return and activity report should be filed with the tax authorities by February 15. An audit opinion or an agreement for audit services should also be submitted by the appropriate deadline.

Social charges

Employers must make social insurance and employment fund contributions, as well as contributions to a trade union if applicable. The total amount payable, which is deductible for profits tax purposes, is 38% to 40% of each employee's gross salary, made up as follows:

Fund Rate

Social insurance 36%

employment 2%

Trade union (if applicable) 2%

Individual Taxation

A resident is defined as an individual who is physically present in Uzbekistan for 183 days or more in a calendar year. Residents are taxed on their worldwide income, while non‑residents are taxed only on their Uzbek sources income.

Taxable income for 1995 and 1996 is taxed at the following rates:

Taxable income (less annual non‑taxable minimum)

Up to 2 annual minimum wage 15%

2 to 5 annual minimum wage 25%

5 to 10 annual minimum wage 35%

Over 10 times annual minimum wage 40%

Social security contributions

1% of the gross salary to the Social Insurance Fund.

Deductions and Exemptions

All income is taxable in Uzbekistan unless it is specifically exempt. The list of specifically exempt income includes alimony, gift, severance and pension income.

Capital gains

Capital gains in the disposal of shares are exempt for taxation. Capital losses are not deductible.

Other taxes and fees

Value Added Tax ("VAT")

VAT was introduced in Uzbekistan on February 15, 1991. The current rate is 17%.

VAT is levied on turnover from the supply of all goods and services (including barter transactions), unless they are specifically exempt. Imports are exempt. Though, VAT is levied on the Uzbek seller's markup of imported goods. Exported goods and services are specifically exempt from VAT. Exported goods are defined as having cleared customs. Exported services are defined as being supplied to a "foreign person". For the determination of whether services are exported, neither the place of providing the services not the place where the benefits are used are considered, only that the purchaser is a foreign person (entity). It could be argued that Uzbek VAT legislation allows representative offices of foreign legal entities (which are non‑resident), paying for services in foreign currency through authorized Uzbek banks to also be classified as "foreign person".

Effective January 1 1996, the exemption on exported goods and services is only applicable if the importing country does not impose VAT on exports to Uzbekistan. This restriction is especially important with respect to some members of the CIS as VAT is charged on exports to member states.

The VAT legislation of Uzbekistan allows a credit for VAT incurred, when such goods or services are "charged to the cost of production".

Excise taxes

Excise taxes are payable by domestic producers and importers of excised goods. The list of excised goods is determined by the Cabinet of Ministers and includes tobacco, jewelry, gasoline, liquor and other goods. Exported goods are exempt. Tax rate vary from 5% to 75%. The amount of excise tax is determined by the taxpayer, based on the volume of goods sold and established tax rates on such goods.

Property tax

The 2% rate tax is based on the historical cost of fixed assets used in production. Legislation specifically includes buildings, machinery, equipment and vehicles. Accumulated depreciation does not reduce the taxable base. The following assets are specifically excluded from he taxable base for property tax purposes:

‑ housing, social and cultural facilities;

‑ environmental protection assets;

‑ agricultural equipment;

‑ transportation networks (including roads and pipeline);

‑ communication and power transmission lines (including

‑ maintenance structures);

‑ communication satellites; and

‑ automobiles.

Profit tax is deductible for profits tax purposes.

Subsurface use tax

Taxes on the mining, and oil and gas industries. Subsurface uses tax is deductible for profits tax purposes.

Land tax

A fee on land owners is imposed at a fixed rate per hectare.

Vehicle fees

A minimal fee on motor vehicle owners is imposed at a fixed rate per horsepower. Individuals must also pay this fee, though only at half the corporate rate. Only vehicles registered for road use are subject to this tax (e.g. not those used for production which would be subject to property tax).

In addition there is a fee on the purchase of vehicles, defined as a percentage of the purchase price of the vehicle excluding VAT or duties, 5% for cars and 10% for trucks, buses, trailers and semi‑trailers.

Road use tax

All entities are subject to road use tax which is applied to gross sales, excluding VAT and excises. For transportation companies a rate of 2% and for all other companies a rate of 1% applies. The tax is deductible for profits tax purposes.

Water use fee

There is a nominal charge for the use of water resources at a fixed rate per cubic meter of water consumed. For most companies, the rate is 0.09 soum per cubic meter. The fee is deductible for profits tax purposes within statutory water use limits.

Local taxes

There are numerous different taxes, though most are insignificant except for the administrative burden. Example of more significant local taxes include:

• Tax on advertising costs. In Tashkent the rate is 5% of total expense.

• Fee for cleaning the local territory, payable by entities and individuals conducting entrepreneurial activities. In Tashkent the rate is 0.5% of gross receipts.

• Fee for the right to trade, payable by entities and individuals conducting retail trade. In Tashkent the rate is two minimum monthly wages per month.

Revenue collection problems¹³

• High tax rates on modest tax bases reduced not only by economic contraction but also by various exemptions.

• Weak tax administration compounded by corruption.

• The effective tax burden on those who comply with the tax code is increased since large numbers of taxpayers successfully evade taxes ‑ equity and efficiency problems.

• Corruption and abuse of authority by poorly paid tax administrators are serious problems.

• Another major cause of poor tax revenues is dollarization and the continued use of barter, payment in kind.

The Investment Policy of Uzbekistan

Priority areas¹⁴

1. Gold‑mining and non‑ferrous (Uzbekistan ranks 4th in the world in terms of gold reserves).

2. Power engineering.

3. Processing of cotton (40% of the gross agricultural production is cotton, however only 10% of produced raw cotton is processes in Uzbekistan, the rest is exported as raw material. The existing textile industry is obsolete).

4. Processing of vegetables and fruits (The production makes up 60% of the total fruit and vegetables production of the former USSR; agricultural infrastructure development needed ‑ processing, transportation, storage facilities, packing).

5. Transport and communication.

6. Tourism (4000 architectural monuments, many of them are under the protection of UNESCO;. world famous cities Samarkand, Bukhara, Khiva; tourism infrastructure is a potential area of investment).

7. Financial and monetary. Create a network of banks and insurance institution.

8. Environmental Protection (degradation of the ecosystem of the Aral Sea, irrational use of water resources).

Guarantees and privileges granted to foreign investors¹⁵

1. If subsequent legislation of the republic of Uzbekistan impairs investment conditions, then the legislation which was valid at the time of making the investment shall apply for a period of time not exceeding 10 years.

2. Companies profit tax shall be reduced by:

• 20%, for an export share of 5-10% of the total production;

• 30%, for an export share of 10-20% of the total production;

• 40%, for an export share of 20 to 30% of the total production;

• 50%, for an export share of 30% or above of the total production.

The purpose here is encourage export oriented manufactures and producers. "The great success stories of economic development in the last decade have been the newly industrialized countries of East Asia, especially the so-called "Four Tigers" (South Korea, Taiwan, Hong Kong, Singapore) and, increasingly, Thailand and China. In these countries, rapid growth of manufactured exports has produced dramatic increase in income. NICs have undertaken a host of interventionist measures to create incentives for export-oriented manufacturing firms, often in particular targeted industries at particular stage of development."¹⁶

The heritage of the old socialist system - exports of primary commodities and raw materials (cotton and cotton products in case of Uzbekistan)- has to be gradually replaced by exports of manufactured goods. "It makes a difference not only because of the recurring problem of gluts resulting in falling process in commodity markets but also because of the greater potential for raising technological capabilities".¹⁷

3. Receipts in hard currency earned by a company due to increase in export production (product, jobs, services) shall be exempt from profit tax.

4. A 25% profit tax shall apply to the profits of Joint Ventures with a foreign capital of above 30%.

5. Joint Ventures with a foreign capital investing into projects in priority industries included in the Investment Program of Uzbekistan shall be exempt form taxation for the first five years of operations.

6. Joint Ventures which specialize in agricultural products and the processing thereof (except for wines and strong alcoholic beverages), consumer products, and construction materials, medical equipment, machines and equipment for agriculture, light and food industries, recycling of waste materials are exempt from taxation for two years from the date of registration.

7. The profit tax base is decrease by 30% of the expenses for environmental protection.

8. Dividend on governmental bonds are exempt from taxation;

9. Joint Ventures in which the foreign investors share accounts for a least 50% shall be exempt of profit tax provided that whole tax amount is re-invested into the development and expansion of production of consumer goods.

10. Exporting companies are exempt of VAT for materials resources used in the production of exported goods (jobs, services)

11. Beginning July 1994 through December 31, 1997 all commercial banks including those with foreign capital, as well as the branches and subsidiaries of foreign banks operating in Uzbekistan are exempt from profits, property, land and vehicle taxes.

V. Intergovernmental Financial Relationship

The Statute of the Republic of Uzbekistan "About Taxes on Enterprises and Entities" establishes revenue sources of the State budget of the Republic of Uzbekistan, State budget of the Republic of Karakalpakstan¹⁸ and local budgets for the following expenditures:

• Social Security Payments;

• Businesses regulation;

• International payments;

• Stabilization of the foreign currency circulation;

• Stimulation of extraction of mineral resources; and

• Environmental protection.

Uzbekistan has a unified statewide tax policy for all layers of government. Local governments are entitled to levy taxes within the format of the state wide tax policy.

Характеристики

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