Ministry of Investment, Industry and Trade of the Republic of Uzbekistan

Pursuant to Clause 4 of the Minutes of the Cabinet of Ministers of the Republic of Uzbekistan No. 204 dated December 4, 2024, the Ministry of Investment, Industry, and Trade, in collaboration with the Ministry of Economy and Finance, the Tax Committee, and other relevant ministries and agencies, was tasked with submitting a draft regulatory legal act to the Cabinet of Ministers within one month. This draft aimed to introduce tax holidays for investors who provide infrastructure for investment projects using their own funds.

In accordance with this mandate, the Ministry of Investment, Industry, and Trade developed and submitted a draft Decree of the President of the Republic of Uzbekistan titled "On Reimbursing Infrastructure-Related Expenses of Investors" (ID-3766) for approval via the Special Information System for Coordinating Draft Regulatory Legal Acts (loyiha.adliya.uz) on December 18, 2024.

Subsequently, the Ministry issued a follow-up request to the Ministry of Economy and Finance, the Ministry of Justice, and the Tax Committee via letter No. 01-14-10921 dated December 16, 2025. In its response (No. 03/41-2-29666 dated December 30, 2025), the Ministry of Economy and Finance noted that, pursuant to Presidential Decree No. UP-138 dated August 19, 2025, expenses incurred by business entities for the construction and subsequent free transfer of social infrastructure facilities are deductible from the corporate income tax base.

The Senate of the Oliy Majlis has approved a draft law aimed at codifying this procedure through amendments and additions to the Tax Code, following the adoption of the primary tax and budget policy objectives for 2026.

To further implement this procedure, the Law of the Republic of Uzbekistan No. ZRU-1108 dated December 25, 2025, introduced a specific provision to Article 306 of the Tax Code. Under this provision, expenses incurred by taxpayers for the construction of social infrastructure networks (electricity, gas, heat, water supply, sewage, and roads) using their own funds are deemed justified, provided these facilities are transferred free of charge to the relevant utility providers and a supporting conclusion from the "Center for Comprehensive Expertise of Projects and Import Contracts" SUE (now the "Center for Increasing the Efficiency of Projects and Procurement" SUE) is submitted to the tax authorities.

As a result, an opportunity has been created not only for entities executing major investment projects but for all legal entities engaged in business to treat these costs as depreciation expenses, thereby deducting them from the taxable base when calculating corporate income tax.