Challenges of International Taxation and Transfer Pricing Regulation in Uzbekistan: Current Status and Directions for Improvement

This article analyses challenges associated with international taxation and transfer pricing regulation in Uzbekistan, including the risk of base erosion, the institutional capacity of tax administration, cross-border financing, share transactions involving non-residents, and the taxation of income derived from subsoil use. Particular attention is paid to potential tax risks arising in the extraction and export of critical raw materials. The article assesses the consistency of existing transfer pricing rules with international standards, taxpayers’ documentation obligations, and the capacity of tax authorities to conduct oversight. It also develops proposals concerning limitations on the deduction of interest expenses, taxation of income from indirect share transfers, and the assessment of the effectiveness of tax incentives.