Tax audit in Uzbekistan: how to prepare and what to do after the audit report

A tax audit is not a verdict: the Tax Code strictly limits how long it can last and gives you the right to contest every conclusion the inspectors reach. What matters is knowing which type of audit you face, filing objections to the audit report on time (you have 10 days) and, if you disagree with the decision, appealing it before it takes effect. For small businesses, a decree of 27 August 2026 declared a three-year moratorium on inspections, with a number of exceptions.

What types of tax audit are there?

Article 137 of the Tax Code lists four types:

• Desk audit — carried out at the tax office based on your returns and the data it already holds. As a rule, inspectors do not visit you, inspect premises or seize documents (Article 138). If discrepancies are found, you receive a request to correct your returns.
• Field inspection — a check of specific obligations: use of cash registers, movement of goods and money, and so on. It lasts no more than 10 days (Article 139).
• Tax audit — a full check of whether taxes for a period were calculated and paid correctly. It is ordered for high-risk taxpayers (Article 140).
• Transfer pricing audit — added from 1 January 2026 for controlled transactions.

Before a desk audit, the tax authority may run an automated pre-audit analysis. If the system finds discrepancies, a notice arrives in your taxpayer's personal account, and you have 10 days to file an amended return or explain the discrepancies. Do not ignore these notices — silence becomes grounds for a desk audit.

Is the moratorium on small business inspections in force?

Yes. Presidential Decree No. UP-175 of 27 August 2026 declared a three-year moratorium on any inspection of small businesses. An inspection during this period is unlawful, and the officials responsible are held liable. The exceptions are:

• inspections within a criminal case;
• inspections of impact on human health and of compliance with labour law;
• inspections based on complaints from citizens;
• inspections related to VAT refunds;
• inspections in connection with the liquidation of a business.

In addition, from 1 January 2027 any repeat inspection within one year, other than a desk audit, may be carried out only with the permission of the Business Ombudsman. If you are a small business and receive an order for an inspection that does not fall under the exceptions, check its grounds immediately and, if necessary, contact the Business Ombudsman. Separately, the Tax Code exempts businesses with an "AAA" sustainability rating from tax audits (except state enterprises and criminal-case inspections).

How must you be notified, and how long does an audit last?

• Tax audit: notice is sent at least 30 calendar days before it starts, with a list of issues and a preliminary list of documents. An audit may start without notice only if there are signs of tax evasion and with the approval of the Tax Committee. It lasts 30 days from delivery of the order; it can be extended to two months, and in exceptional cases to three, but the total may not exceed six months (Articles 140–142).
• Field inspection: up to 10 days from the date stated in the order.
• Any audit is carried out on the basis of an order by the head of the tax authority stating the inspectors, timing, purpose and period under review. Ask to see the order and take a copy.

A repeat audit of the same taxes for the same period is prohibited, except where new circumstances come to light (Article 143).

How to prepare for an audit

1. Study the order or notice: the type of audit, period, taxes and issues listed.
2. Appoint one person to deal with the inspectors and tell staff that documents are handed over only through them.
3. Reconcile your returns with your personal account data, electronic invoices and bank statements. It is better to fix errors for the period under audit by filing amended returns before the audit begins — during a tax audit you cannot amend returns for that period (Article 140).
4. Prepare documents on the issues in the notice: contracts, acceptance certificates, primary records, calculations supporting any tax benefits.
5. Meet document requests on time: under Article 146 documents must be provided within five days. If you cannot make it, notify the inspectors in writing by the next day, giving reasons and a deadline — the head of the tax authority may extend it.

You certify copies yourself — the tax authority may not demand notarised copies. Nor may it request again documents you already submitted during earlier desk audits or field inspections.

What are your rights during an audit?

Article 21 of the Tax Code gives you the right to:

• be present during a field inspection or tax audit carried out on your premises;
• review the audit materials and receive the audit report;
• give explanations and be represented by a tax consultant or another representative;
• refuse to comply with demands that do not conform to the Tax Code;
• claim compensation for losses caused by unlawful actions of the tax authorities.

Any irremovable contradictions and ambiguities in tax legislation are interpreted in favour of the taxpayer (Article 13). Evidence obtained in breach of the Code may not be used (Article 158).

What to do after the report: objections and review

The tax audit report is handed to you within three days after the audit ends. From then on, deadlines matter:

1. 10 days for objections. If you disagree with the facts or conclusions, file written objections to the whole report or parts of it and attach supporting documents (Article 156).
2. Review of the materials. The head of the tax authority reviews the report no earlier than 10 and no later than 15 days after it was drawn up; you are notified of the date at least two working days in advance. You may take part in person, through a representative or by video link. Even without written objections, you are entitled to give explanations (Article 158).
3. Decision. It is taken within five days after the review and delivered within two days. It sets out additional tax assessed, penalty interest, fines and how to appeal (Article 159). The decision takes effect one month after delivery (Article 160).

Example. Suppose an audit report assesses an extra UZS 150 million of VAT because of a "questionable" supplier. Within 10 days you file objections with the contract, transport documents and evidence that the supply was real. If the head of the inspectorate rejects them, you still have a month to appeal the decision before it takes effect.

How to appeal the decision and suspend collection

A decision on audit results can be appealed to a higher tax authority or directly to court (Article 231).

• A complaint to a higher tax authority is filed through the inspectorate that issued the decision, within one month of the day you learned your rights were violated (Article 232). A decision on a complaint about tax audit results is taken within one month, which may be extended by no more than 15 days (Article 235).
• An application to the administrative court may be filed within six months of the moment you learned of the violation (Article 186 of the Code of Administrative Court Procedure).
• Suspending collection. Filing a complaint with the tax authority or the court suspends enforcement of the decision, including collection of the additional taxes and fines, until the complaint is decided or the court's decision takes effect. You must notify the tax authority whose decision you are challenging and attach proof of filing.

If the decision is overturned, the taxes and fines paid are refunded with interest at the Central Bank refinancing rate (Article 230).

When should you bring in a lawyer?

An accountant can usually handle a desk audit request alone. Legal help is especially important if:

• a tax audit or transfer pricing audit has been ordered — it is a full review, and your position on contentious issues should be built in advance;
• the additional assessments are significant or the tax authority questions whether deals with counterparties were genuine;
• there are signs of tax evasion and a risk of a criminal case — any explanations to inspectors must then be given with great care;
• you are a small business and believe the inspection breaches the moratorium.

The tax law team can prepare objections to the report and represent you at the review and in appeals before the tax authority and the court.

In brief

• Types of audit: desk audit, field inspection (up to 10 days), tax audit (30 days, no more than six months in total) and transfer pricing audit.
• Small businesses: under Decree UP-175 of 27 August 2026, a three-year moratorium on inspections, save for exceptions.
• Notice of a tax audit is given at least 30 days ahead; requested documents are due within five days.
• You have 10 days to object to the report; the decision takes effect one month after delivery.
• Complain to a higher authority within one month or to court within six months; filing suspends collection.

Photo: Unsplash, Wikimedia Commons (CC0)