Subsoil use tax and rent tax in Uzbekistan
A subsoil user calculates the ordinary tax from the value or volume of extraction and the rate for the relevant mineral. Legal entities file monthly. Organisations extracting metals or hydrocarbons may also be subject to a rent tax of at least 25% (Tax Code, Article 454-5) on positive rent income.
In brief:
- the ordinary tax applies to legal entities and individuals (Tax Code, Article 449) that extract minerals or recover them from technogenic mineral formations;
- the taxable base and rate are determined separately for each mineral, and the rent tax is also calculated separately for each licensed area;
- a legal entity files and pays the ordinary tax monthly by the 20th of the following month and files the rent tax quarterly by the 20th;
- an individual files and pays the ordinary tax by 1 February of the following year;
- before calculating, match the mineral, its use, the licensed area, any local coefficient, and any project-specific rate.
Who pays subsoil use tax
Any legal entity or individual that extracts minerals from the subsoil in Uzbekistan or recovers minerals from technogenic mineral formations is a subsoil use taxpayer. The Tax Code treats subsoil use tax and the special mining rent tax as two separate taxes (Article 17). Liability for the ordinary tax therefore does not, by itself, answer whether the rent tax also applies.
An individual conducting artisanal mining of precious metals in compliance with the statutory conditions is not a taxpayer for that activity. The exemption does not remove the conditions of the permit: a report on the volumes of precious metals and gemstones extracted and sold must be submitted to the Subsoil Use Centre within 30 days (Subsoil Law, Article 122) after the end of the year or termination of the permit.
The same activity-based test applies to a foreign company. If a legal entity extracts minerals in Uzbekistan, its legal form or residence does not by itself exclude the tax. A production sharing agreement may establish special terms, discussed separately below.
What is taxable and which volumes are excluded
The taxable object depends on the mineral. As a general rule, it is the volume extracted or recovered. For ferrous, precious, non-ferrous and radioactive metals, as well as rare and rare-earth elements, the object is the volume actually sold. This list of taxable objects (Tax Code, Article 450) applies separately to each mineral.
Technological losses arising throughout extraction, primary treatment, processing, and transport are deducted from the extracted volume. The deduction is limited to standards approved by the competent authority or, if none exist, standards set by the taxpayer. Excess losses are not deductible. For natural gas, technological losses can include gas reinjected into a reservoir to maintain pressure or recover hydrocarbons in a closed technological cycle.
The following are not taxable objects:
- common minerals extracted within the taxpayer’s allocated land plot and used for its own household and operational needs;
- non-metallic minerals recovered during duly authorised riverbed clearance and bank reinforcement, except for the volume sold.
A landowner, land user, or owner may extract construction minerals and aggregates within their plot for personal, household, or other non-business purposes without a permit (Subsoil Law, Article 124). Those minerals may not be transferred to another person. By its terms, this rule does not cover commercial extraction or sale.
How to determine the taxable base
The taxpayer determines the base separately for each mineral on a cumulative basis from the start of the period. The general base is the value of the extracted volume; for the listed metals and elements, it is the value of the volume actually sold. The weighted-average selling price (Tax Code, Article 451) equals sales revenue excluding VAT and excise tax divided by the physical sales volume.
The next step depends on the facts:
- where part of the mineral is used for the taxpayer’s own needs, the weighted-average selling price is applied to the entire extracted volume;
- if no sale occurs in the current period, the weighted-average price from the most recent period with a sale is used;
- if there has been no sale since extraction began, the base is production cost plus 20%, followed by an adjustment when the first sale occurs using that period’s weighted-average price;
- if the entire volume is used for the taxpayer’s own operational or production needs, the base is also production cost plus 20%;
- if gas, oil, or gas condensate is processed by the taxpayer or on a tolling basis, the base is the selling price of the processed products less further processing and transport costs.
Separate rules apply to gold, silver, platinum, palladium, copper, zinc, lead, and molybdenum. The base is determined for the metal contained in ore, concentrate, or the finished product and generally uses the higher of two prices (Tax Code, Article 451-1): the arithmetic-average exchange price or the weighted-average selling price. LBMA data are used for gold, silver, palladium, and platinum, while LME data are used for the other metals. The tax authority publishes its calculated prices by the 10th of the following month.
For ore and concentrate, agreed costs of subsequent smelting, refining, and transport are generally deducted from the calculated value. For gold and copper, the default rule in Article 451-1 does not provide those deductions, although the taxpayer may elect a calculation that deducts them. The selected method must correspond to the accounting records and the agreed amount of expenses.
This article does not address the corporate income tax treatment of geological-study costs. The article on corporate income tax explains the general recognition and substantiation of expenses. It is relevant when the same project requires both resource-tax and profit-tax accounting.
Subsoil use tax rates in 2026
The rate must be matched to the exact taxable mineral. The current rates by mineral type (Tax Code, Article 452) are reproduced in full below. The changes section explains the rules for certain state enterprises and the temporary gypsum relief.
| Group and taxable object | Rate | Additional condition |
| Oil, natural gas, and gas condensate | 10% | — |
| Utilised natural gas, volume sold | 5% | — |
| Underground-gasification gas | 2.6% | — |
| Coal and oil shale | 4% | — |
| Gold, silver, palladium, platinum and platinum group metals, osmium, and other precious metals | 7% | — |
| Copper, lead, zinc, molybdenum, nickel, cobalt, tin, antimony, mercury, and aluminium | 7% | — |
| Other non-ferrous metals | 10% | — |
| Uranium, thorium, and radium | 8% | — |
| Tungsten | 2.7% | — |
| Rhenium, selenium, tellurium, indium, bismuth, tantalum, niobium, beryllium, lithium, rubidium, caesium, gallium, titanium, zirconium, hafnium, thallium, and cadmium | 8% | — |
| Lanthanum and lanthanides, yttrium, and scandium | 8% | — |
| Other radioactive metals, rare elements, and rare-earth elements | 8% | — |
| Turquoise, listvenite, rhodonite, serpentinite, marble onyx, cacholong, jasper, chalcedony, agate, hematite, and other rough gemstones and ornamental stones | 10% | — |
| Iron | 2% | — |
| Titanium, manganese, chromium, vanadium, and other ferrous metals | 4% | — |
| Mineral pigments | 5.5% | — |
| Iodine | 4.8% | — |
| Mineral salts, carbonate feedstock, mineral fertilisers, and other mining-chemical feedstock | 3.5% | At least 6,591 soums/m³ |
| Fluorspar, feldspar feedstock, quartz and quartzite, kaolin to the extent sold, and natural graphite | 7.9% | — |
| Glass feedstock, quartz sand, and brucite marble | 3% | — |
| Talc, soapstone, talc-magnesite, wollastonite, asbestos, barite, vermiculite, moulding feedstock, and felsite | 4% | — |
| Serpentinite and other mining feedstock | 5% | — |
| Cement feedstock other than limestone for cement production | 5% | — |
| Limestone for cement production | 7,062 soums/tonne | Fixed rate |
| Dimension stone, rubble stone, shell limestone, specified limestone, dolomite, crushed stone, basalt, granodiorite, granosyenite, syenite, porphyry, gabbro, shale, carbonate feedstock, and travertine | 5% | At least 6,591 soums/m³ |
| Blocks of natural facing stone | 5% | At least 10,700 soums/m³ |
| Marble | 5% | At least 21,400 soums/m³ |
| Granite | 5% | At least 32,100 soums/m³ |
| Gypsum stone, gypsum, anhydrite, and ganch | 5% | At least 17,066 soums/tonne |
| Brick and tile feedstock, loess, and loess-like rocks | 5% | At least 4,943 soums/m³ |
| Construction sand, sandstone, and sand-gravel mix | Fixed | At least 5,350 soums/m³ |
| Limestone for lime, porcelain and expanded-clay feedstock, marl, argillite, volcanic rocks, pelitic tuffite, basalt for mineral fibre, and the other listed non-metallic materials | 5% | — |
| Minerals recovered from technogenic mineral formations | 50% of the primary rate | Based on the primary mineral |
A district or city Kengash may apply a coefficient of up to 1.3 to fixed rates for non-metallic construction materials, except limestone used for cement. The fixed amount should therefore be checked against Article 452 and the decision applicable at the extraction location.
How to calculate the ordinary tax
The ordinary tax equals the taxable base multiplied by the rate. For a mineral subject to a fixed minimum, also multiply the physical volume by the minimum amount per unit and pay the higher result. This comparison is required by the calculation procedure (Tax Code, Article 454).
Example. A company sells 1,000 m³ of construction stone at a weighted-average price of 50,000 soums/m³ excluding VAT and excise tax. The base is 50,000,000 soums and the 5% calculation is 2,500,000 soums. The minimum is 1,000 × 6,591 = 6,591,000 soums. The payable amount is 6,591,000 soums because it exceeds the percentage result. If the local Kengash has adopted a coefficient, apply it to the minimum first.
Own-use example. If a mineral is used entirely in the taxpayer’s own production and its production cost is 100,000,000 soums, the base is 100,000,000 × 120% = 120,000,000 soums. At a 5% rate, the tax is 6,000,000 soums. The production cost in this example is an assumption, not a statutory amount.
Ordinary tax filing and payment deadlines
For a legal entity, the tax period is a quarter and the reporting period is a month. For an individual, both are the calendar year. These periods are set separately (Tax Code, Article 453), so a legal entity’s monthly return is cumulative within the quarter.
| Taxpayer and tax | Reporting period | Filing deadline | Payment deadline |
| Legal entity, ordinary tax | Month | By the 20th of the following month | By the 20th of the following month |
| Individual, ordinary tax | Year | By 1 February of the following year | By 1 February of the following year |
| Special rent tax with a positive base | Quarter | By the 20th of the following month; annual return by 1 March | Same deadlines |
| Special rent tax with a rent loss | Year | By 1 March of the following year | Taxable base is zero |
The ordinary return is filed at the place of tax registration; for non-metallic construction materials it is filed at the extraction location. Do not confuse it with the sectoral report: the holder of a solid-mineral extraction permit submits an annual report by 31 March (Subsoil Law, Article 61) to the Subsoil Use Centre.
This article does not calculate land tax on a subsoil-use site. The land tax article explains who files for land and when payment is due. It is relevant if the permit is accompanied by a right to a separate land plot.
Who pays the special mining rent tax
The special rent tax applies to legal entities extracting precious, non-ferrous, or radioactive metals, rare or rare-earth elements, or recovering them from technogenic mineral formations, as well as those extracting natural gas, gas condensate, or oil. This is the exhaustive class of taxpayers (Tax Code, Article 454-1); individuals are outside it.
A legal entity operating under a production sharing agreement is not a rent-tax payer. For a foreign investor under such an agreement, ordinary subsoil use tax is determined by the agreement as a percentage of the volume of raw materials or the value of production and may be paid in cash or in kind. This special regime (Tax Code, Article 476) must be read with the agreement itself.
The object of the special tax is rent income from sales (Tax Code, Article 454-2) of extracted metal or hydrocarbon feedstock. Possession of a permit alone does not produce a positive base: the income and allowable expenses for the licensed area must first be calculated.
How to calculate rent income and its taxable base
Rent income equals revenue from the sale of extracted metals or hydrocarbons, excluding VAT and excise tax, less capital and operating expenses directly connected with extraction. The transaction price is subject to transfer-pricing requirements. This is the rent-income formula (Tax Code, Article 454-3).
| Included as operating expenses | Excluded from operating expenses | Condition |
| Raw materials, supplies, heat, and energy | Depreciation and the investment deduction | Must relate to extraction and primary processing |
| Inventory and non-depreciable property | Marketing and advertising | Documentary and economic substantiation required |
| Fuel, transmission, and transformation of energy | Research and development | — |
| Licence fees and lease payments | Remuneration of governing bodies, administrative staff, and consultants | — |
| Production workers’ remuneration | Response to emergencies caused by the taxpayer | — |
| Expenses required by law | Training, mobile communications, and internet | — |
| Taxes and charges on extraction operations | Provisions and voluntary insurance | — |
| Work and services supplied by third parties | Interest and other finance costs | Includes interest capitalised into capital expenditure |
Capital expenditure is recognised if the technological conditions for development of the licensed area provide for it, and only in the manner and within the limits set by those conditions. Income and expenses unrelated to extraction, financial-market transactions, hedging, interest, and dividends are excluded. Budget subsidies, by contrast, are included in rent income.
The taxable base is positive rent income calculated cumulatively and separately for each licensed area. If the result is negative, the base is zero. An accumulated rent loss (Tax Code, Article 454-4) can be carried forward and indexed under the statutory formula, but any balance left when the permit ends is not reimbursed.
Direct separate accounting applies to multiple licensed areas. Areas may be grouped where they form one technological project for extraction or subsequent processing and the grouping is agreed with the competent authorities. The general separate-accounting rules (Tax Code, Article 80) require the allocation to be supported by accounting records.
An enterprise with foreign investment may determine the base in US dollars. The average annual exchange rate used for a rent loss is the average of the Central Bank rates on 1 January and 31 December. When the return is filed, the foreign-currency base is converted into soums at the Central Bank rate on the filing date.
The first tax period starts on the date the extraction permit is received. If the permit is issued after 1 July, the first period ends on 31 December of the following calendar year. Historical costs directly connected with the area—obtaining rights and permits, geological study, and preparatory extraction work—may be included in that first period. Rent-tax income and expenses are subject to annual audit.
Example. A project’s revenue from metal sales excluding VAT and excise tax is 12,000,000,000 soums. Allowable capital expenditure is 3,000,000,000 soums and operating expenses are 4,000,000,000 soums. Rent income and the taxable base are 5,000,000,000 soums. At the minimum 25% rate, the tax is 1,250,000,000 soums. If the project has an allowable accumulated rent loss of 800,000,000 soums, the base after relief is 4,200,000,000 soums and the tax is 1,050,000,000 soums.
Rent tax rate, filing, and payment
The minimum rate is 25% of the taxable base. When the right to use a commercially significant area for geological study or extraction of metals or hydrocarbons is tendered, the organiser or bidders may propose a higher rate. The proposed higher rate then applies.
The tax period is the calendar year and the reporting period is a quarter. This rent-tax timetable (Tax Code, Article 454-6) differs from monthly ordinary-tax filing.
With a positive base, a cumulative quarterly return is filed by the 20th of the following month, and the annual return is due by 1 March. Payment is due on the same dates. With a rent loss, one annual return is filed by 1 March. The filing and payment procedure (Tax Code, Article 454-7) requires a foreign-currency base to be converted at the Central Bank rate on the filing date.
Payments outside the two taxes
The taxes do not replace permit-related special payments. The Subsoil Law separately identifies three payment types (Article 160): an application-review charge, a payment resulting from an auction or tender, and an annual licence payment for geological study. The amount of the first two depends on the applicable procedure or tender outcome.
The annual licence payment is payable by the holder of a geological-study permit. Per hectare, it is 10% of one BCU, the base calculation unit, or 44.000 soums for principal minerals, and 15% of one BCU, or 66.000 soums, for non-metallic minerals. The first-year payment is due within 30 days (Subsoil Law, Article 161) after receipt of the permit, and later payments are due by 31 March each year. A partial first or final year is prorated.
Licence-payment example. For geological study of a principal mineral over 100 hectares, the annual payment is 100 × 44.000 = 4,400,000 soums. For a partial year, that result is apportioned over the period for which the permit is in effect.
The signature bonus and commercial-discovery bonus are no longer separate current payments: they were abolished from 1 January 2022 (Decree UP-6319 of 6 October 2021). A payment formed by an auction or tender price should be classified under the tender documents, not labelled as one of the abolished bonuses.
Liability for errors and late compliance
Late payment accrues interest for each day (Tax Code, Article 110), starting on the day after the deadline. The daily rate is 1/300 of the Central Bank refinancing rate then in effect, applied to the arrears.
The main financial and administrative consequences are:
- concealment or understatement of the base carries a fine of 20% of the concealed base; incomplete reporting of extracted mineral volumes is expressly included in the definition of the violation (Tax Code, Article 223), and the tax itself is assessed in addition;
- non-payment resulting from an incorrect calculation or other unlawful act generally carries a fine of 20% of the underpayment (Tax Code, Article 224), unless a more specific offence applies;
- a late return carries 10 BCUs, or 4.400.000 soums, for an officer, or 3 BCUs, or 1.320.000 soums, for a microfirm or small enterprise; if returns for several taxes are late in the same month, one administrative fine (Code of Administrative Liability, Article 175) applies;
- extraction without a permit (Code of Administrative Liability, Article 70-2), except for groundwater and minerals in riverbeds, carries 50–70 BCUs for an individual or 100–150 BCUs for an officer, with confiscation of the instrument or subject of the offence.
Failure to pay statutory charges and a sectoral reporting violation not remedied within 30 days are also subsoil-use violations (Subsoil Law, Article 163). A tax penalty, an administrative fine, and consequences for the permit arise on different grounds and may be enforced by different authorities.
What changed in 2025–2026
- From 1 January 2026 through 31 December 2027, Resolution PP-295 of 4 October 2025 allows domestic industrial enterprises that extract gypsum feedstock for their own needs and manufacture finished construction materials from it to apply 50% of the ordinary rate.
- For 2026, Resolution PP-388 of 26 December 2025 set higher rates for certain state enterprises: NMMC and AMMC pay 10% on gold and 15% on palladium, silver, and copper; Navoiyuran pays 16% on uranium; and Uzbekneftegaz pays 15% on oil, natural gas, and gas condensate.
- From 1 January 2027, Decree UP-95 of 19 May 2026 provides for proactive preparation of subsoil use tax returns for non-metallic construction materials. The current filing procedure continues until that date.
What to check before calculating
Before preparing a return, build a map of mineral, licensed area, volume, price, rate, and deadline. For solid minerals, records must substantiate extraction, losses, waste, production, dispatches, and timely tax declaration; these are part of the subsoil user’s duties (Subsoil Law, Article 59). For hydrocarbons, separately check measurements for commercial and tax accounting and accurate extraction records (Subsoil Law, Article 94).
Use this sequence:
- identify the exact mineral name in the permit and Article 452 of the Tax Code;
- determine whether the extracted volume or the volume actually sold is taxable;
- substantiate allowable technological losses;
- calculate the weighted-average, exchange-based, or cost-based base under the applicable rule;
- check the per-unit minimum, the local Kengash decision, and any enterprise-specific rate;
- calculate rent income separately for each licensed area and reconcile any accumulated rent loss;
- reconcile the tax figures with production records and the compliance calendar before filing.
Frequently asked questions
How does the special rent tax differ from subsoil use tax?
The ordinary tax is based on the value or volume of the extracted or sold mineral and the rate in Article 452 of the Tax Code. The special rent tax applies to legal entities extracting specified metals and hydrocarbons and is charged on the positive difference between sales income and allowable capital and operating expenses. The same organisation can therefore calculate both taxes, but with different bases and filing periods.
Is tax due if the mineral has not been sold?
No sale does not always eliminate the taxable base. For minerals whose taxable object is extracted volume, use the price from the most recent period with a sale. If no sale has occurred since extraction began, use production cost plus 20% and adjust when the first sale occurs. Full own use also uses production cost plus 20%. For metals taxed on actual sales volume, first apply the special rule in Article 450.
Do artisanal miners pay subsoil use tax?
An individual is not a taxpayer for artisanal mining of precious metals when all statutory conditions are met. This does not remove the permit, mining-method, and sectoral reporting duties. The report on extracted and sold volumes must be submitted to the Subsoil Use Centre within 30 days after the end of the year or termination of the permit.
How is a local coefficient applied to a fixed rate?
A district or city Kengash coefficient applies to the fixed rate for a non-metallic construction material, except limestone for cement production, and cannot exceed 1.3. Find the decision for the extraction location and period, multiply the fixed amount per unit by the coefficient, and compare that minimum with the percentage calculation. The higher result is reported.
When are the two tax returns due?
A legal entity files and pays the ordinary tax monthly by the 20th of the following month. With a positive rent-tax base, it files cumulatively each quarter by the 20th of the following month and files the annual result by 1 March. With a rent loss, it files one annual return by 1 March. The production report due to the Subsoil Use Centre by 31 March is a separate obligation.
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