Estonian Company Run from Uzbekistan: Tax Rules

Many people living in Uzbekistan form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from Uzbekistan. The Tax Code of Uzbekistan looks at where a company is actually managed: a foreign legal entity whose place of actual management is Uzbekistan is a tax resident of Uzbekistan, unless a tax treaty provides otherwise. An Uzbek resident who holds more than 25 percent of a foreign company is a controlling person under the controlled foreign company rules. And the Estonia–Uzbekistan tax treaty leaves a company resident in both countries to an agreement between the two tax authorities. This guide sets out these rules with the official texts, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask an Uzbek tax adviser before you form or buy the company. We read the Tax Code of the Republic of Uzbekistan of 30 December 2019 in its current Russian text on lex.uz, the national database of legislation of Uzbekistan, and the Estonia–Uzbekistan tax treaty in Riigi Teataja, on 22 October 2026; the English wording of the Code below is our translation.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Uzbekistan: the company side

Resident. Tax residents of Uzbekistan include foreign legal entities whose place of actual management is the Republic of Uzbekistan, unless a tax treaty of Uzbekistan provides otherwise (Tax Code, Article 33, point 3).
When management is in Uzbekistan. At least one of two conditions is enough: the executive body regularly acts for the entity from Uzbekistan — not regularly if the activity there is substantially smaller than in another state; or its senior officers mainly exercise executive management of the entity in Uzbekistan, which includes decisions on its current activity (Article 34, first part).
What does not count. Preparing or taking decisions of the general meeting of shareholders, preparing board meetings and separate planning and control functions in Uzbekistan do not by themselves make Uzbekistan the place of actual management (Article 34, second part).
Own staff in a treaty country. Uzbekistan is not the place of actual management when the entity works in its state of permanent location with its own qualified staff and assets and Uzbekistan has a tax treaty with that state (Article 34).
When both countries meet the conditions. If it is documented that the executive body or the senior officers meet the first-part conditions for both Uzbekistan and another state, Uzbekistan is the place of management if the entity's accounting or management accounts, its records or its day-to-day personnel management are kept in Uzbekistan (Article 34).

An Estonian OÜ is a foreign legal entity for this rule. If you live in Uzbekistan and run the company from there as its only board member, the first part of Article 34 can be met. Your Uzbek tax adviser answers that with the facts of your case.

In Uzbekistan: the owner side

Resident individual. An individual actually present in Uzbekistan for more than 183 calendar days in total in any consecutive twelve-month period starting or ending in the tax period is a tax resident (Article 30, second part).
Controlled foreign company. A foreign legal entity that is not a tax resident of Uzbekistan and whose controlling persons are Uzbek tax residents is a controlled foreign company (Article 39).
Controlling person. An Uzbek tax resident whose share in the foreign company is more than 25 percent, or more than 10 percent when all Uzbek tax residents together hold more than 50 percent, is a controlling person (Article 40, first part).

How the profit of a controlled foreign company is then taxed in your hands is a question for your Uzbek tax adviser.

The Estonia–Uzbekistan tax treaty

A company resident in both countries. The competent authorities shall endeavour to settle the question by mutual agreement; without agreement, the company is not treated as a resident of either country and gets no treaty benefits (Convention signed in New York on 28 September 2012, Article 4(3)).
Dividends. The country of the paying company may tax dividends at no more than 5 per cent of the gross amount if the recipient is a company holding directly at least 25 per cent of the capital, and 10 per cent in all other cases (Article 10(2)).
Directors' fees. Fees for a member of the board of a company resident in the other country may be taxed in that country (Article 16).

Whether the Multilateral Instrument changes these articles is a question for your Uzbek tax adviser. We do not give that ruling.

What to decide before you form or buy the company

Where the management board works from. Regular executive work from Uzbekistan meets the first condition of Article 34.
Who owns the company, and where they live. An Uzbek resident with more than 25 percent is a controlling person under Article 40.
How you take money out. A dividend, a board fee and a salary fall under different articles of the treaty.

What we do on the Estonian side

online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. Uzbek tax returns and Uzbek tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

The two company forms side by side — founders, charter fund, share transfer and the profit tax: Estonian OÜ or Uzbek OOO.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; Uzbek tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in Uzbekistan if I run it from Uzbekistan?

It can be. The Tax Code of Uzbekistan counts a foreign legal entity as a tax resident when its place of actual management is Uzbekistan, unless a tax treaty provides otherwise — for example when its executive body regularly acts from Uzbekistan or its senior officers mainly manage it there (Articles 33 and 34). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). Under the Estonia–Uzbekistan tax treaty, the two tax authorities try to settle the residence of a company resident in both by mutual agreement; without agreement it gets no treaty benefits (Article 4(3)). An Uzbek resident with more than 25 percent of a foreign company is a controlling person under the controlled foreign company rules (Article 40). Ask an Uzbek tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Uzbekistan: what is taxed where