Permanent Establishments: Key Features And Taxation

Today's Legal Highlight is dedicated to such complex topic as permanent establishment ("PE"). Under Uzbek Law, PE is not considered as separate legal entities and used solely for tax purposes.

Below we briefly touch upon those provisions on PE set in article 20 of the Uzbek Tax Code that are either different from or supplement the OECD Model Tax Convention on Income and Capital.

It should be noted that the principle of supremacy of international law is recognized in the Uzbek legislation. This principle is fixed, among others, in article 4 of the Uzbek Tax Code. Hence, one should always consult relevant Double Tax Treaty that Uzbekistan has concluded with the other states to see whether there are any discrepancies.