Tax audits

The tax authorities conduct desk and field tax inspections, tax audits and transfer-pricing inspections. A desk inspection lasts up to 60 days, a field inspection up to 10 days (Article 139 of the Tax Code), and a tax audit normally up to 30 days (Article 141 of the Tax Code), although it can be extended.

In brief:

• The Tax Code identifies four types (Article 137 of the Tax Code); a separate regulation also governs remote inspections of digital labelling.
• The general period open to inspection is limited by a three-year limitation period (Article 88 of the Tax Code), unless a special rule provides otherwise.
• Field inspections and tax audits are registered in the control system and conducted after notifying the Business Ombudsman.
• Since 28 August 2026, a three-year moratorium on inspections of small businesses has applied, subject to expressly listed exceptions.
• A company should verify the grounds, authority and scope of the inspection, preserve every notice, and submit documents or objections on time.

Updated: 05 September 2026

What types of tax inspection are there

The Tax Code provides for four types of tax inspection, while a subordinate regulation establishes a special remote inspection for digital labelling. Every tax inspection is intended to check compliance with tax legislation by a taxpayer, levy payer or tax agent.

A business with an “AAA” high sustainability rating benefits from an exemption from inspections (Article 137 of the Tax Code), except for inspections in criminal cases. The exemption does not cover state enterprises or legal entities in which the state holds at least 50%.

A remote inspection is conducted under an order without prior notice to the taxpayer, but the Business Ombudsman must be notified on the day of the inspection. No inspector travels to the premises: its scope is confined to data on mandatory digital labelling.

This article does not cover the special review of prices in controlled transactions. The article on transfer pricing explains the controlled-transaction criteria, documentation and separate inspection procedure. It is relevant when a company transacts with related or foreign persons.

How a taxpayer is selected for inspection

A tax audit is associated with a high degree of tax risk. A field inspection may begin following risk analysis or on the basis of specific information about a possible breach. The system uses tax returns, personal-account records, information from public authorities, earlier inspection materials, court and law-enforcement data, complaints and other lawful sources.

The category thresholds and rule for assigning an audit are set by the risk regulation. Risk is normally assessed once every six months. The criteria must be published on the Tax Committee website, and a taxpayer may submit explanations through its online account. The general state-control system also excludes inspections at a low risk level.

Example. Assume that the system assigns a company an 85% risk score. That result falls within the 81–100% band, so the company is classified as high risk and may be selected for a tax audit. The score itself does not prove an offence: any breach and amount must be established through the procedure prescribed by law.

How a desk tax inspection is conducted

A desk inspection is conducted at the tax authority using returns and information it already holds. During an ordinary desk inspection, four actions (Article 138 of the Tax Code) are prohibited:

• entering the taxpayer’s territory;
• inspecting its territory or premises;
• demanding documents from, or summoning, the taxpayer;
• seizing its documents or objects.

An exception applies to a desk inspection concerning a refund or reimbursement of value added tax. A pre-audit analysis may precede the desk inspection. This is an automated comparison of data without taxpayer participation and without an inspection order. It is not conducted for a period that is or has already been covered by a tax audit.

The desk inspection itself requires an order from the head or deputy head of the tax authority. The order identifies the taxpayer and inspectors, duration, period under review and taxes concerned. Its total duration may not exceed 60 days, and the same taxes for the same period may be inspected again only if new circumstances emerge.

If discrepancies or errors are found, the tax authority issues a formal demand. Within five days (Article 138 of the Tax Code) after receipt, the taxpayer submits an amended return or a substantiated response with supporting documents. An opinion from a tax-consulting organisation may accompany the response.

What to do after receiving a discrepancy notice

First identify exactly what was received: a pre-audit analysis notice or a demand issued after a completed desk inspection. For an electronic document, time does not necessarily run from the date it was actually opened. It is deemed received when read, but no later than three days (Article 19 of the Tax Code) after dispatch. Registered post is deemed received after five days.

A five-day deadline applies to an amended return or documented explanation responding to a completed desk-inspection demand. The reply should reconcile each discrepancy to a register, primary document, invoice, payment or other verifiable record instead of offering only a general explanation.

Lex.uz currently publishes inconsistent rules on pre-audit analysis. The current Tax Code text (Article 138) still contains a ten-day duty to provide an amended return or explanation. However, the later Decree UP-95 of 19 May 2026 expressly abolished that duty from 1 July 2026 and introduced a notice for medium-risk taxpayers: if the identified shortcomings are remedied within one month, no inspection is conducted. Because of this textual conflict, this article does not present the former ten-day period as indisputably operative. A company should preserve the notice and confirm remediation within the period set by the newer rule and by the document received.

How a field tax inspection is conducted

A field inspection concerns specific tax duties and the business’s factual operations. Inspectors may analyse accounting records and movements of inventory and cash, conduct time-and-motion observations, and check cash-register equipment and payment terminals.

The list of grounds for a field inspection includes:

• a risk of a tax-law breach detected by the risk-management system;
• complaints from individuals or legal entities about tax or currency breaches;
• reports in the media;
• the need for additional information to conduct an objective desk inspection;
• the need for additional control during special VAT-payer registration;
• an incomplete response to a currency-monitoring request;
• information from courts, law-enforcement agencies or other public authorities;
• breaches of digital-labelling rules or notification requirements detected by inspectors, or business activity without registration;
• a specified case involving imported food remaining unsold for a long period and meeting the prescribed criteria;
• failure to remedy specified breaches within three days of an official warning, or detection of the breach again.

The inspection is conducted under an order and lasts no more than 10 days (Article 139 of the Tax Code). It begins on the date stated in the order and ends when the report is delivered or sent through the taxpayer’s online account. Field inspections and audits require notice to the Business Ombudsman, except for an inspection of an individual conducting unregistered business.

How a tax audit is conducted

A tax audit is the most extensive check of whether taxes were correctly calculated and paid for a defined period. It is assigned to a taxpayer or tax agent with high risk. The tax authority normally sends notice 30 calendar days in advance (Article 140 of the Tax Code), stating the start date, issues and a preliminary list of documents. If there are signs of tax evasion, an audit may begin without notice with the Tax Committee’s approval.

An audit begins when the order is served. The ordinary limit is 30 days (Article 141 of the Tax Code). It may be extended to two months, or in specified cases to three months, while the overall limit (Article 142 of the Tax Code) is six months. Grounds for an extension are:

• obtaining documents or information;
• receiving information from foreign public authorities;
• conducting an expert examination;
• translating foreign-language documents.

A repeat audit of the same taxes for the same period is prohibited unless new circumstances (Article 143 of the Tax Code) emerge. During the audit, the taxpayer may not amend returns for the period under review.

What period may be inspected

The general limitation period for a tax obligation is three years (Article 88 of the Tax Code) after the end of the relevant tax period. If an obligation arises from an event or action, the period is normally measured from that event or action. For a relief, deduction, rate or payment deferral subject to continuing conditions, the period may be lengthened by the duration of those conditions.

A desk inspection covers periods for which the limitation period has not expired. An audit covers the period following the previous audit within the same limitation period. In a voluntary liquidation, the audit may cover no more than the three years of activity immediately preceding the year of inspection.

Tax returns and their attachments must be retained for at least three years (Article 22 of the Tax Code) after the relevant calendar year. Accounting records supporting a relief or another regime subject to long-running conditions should be kept longer where needed to cover the extended limitation period.

What to check before admitting inspectors

A business inspection must be registered in the “Yagona davlat nazorati” information system. An unregistered inspection is unlawful. Before it starts, the inspector explains its purpose to the manager, presents official and special identification, delivers copies of the order and programme against acknowledgement, and explains how the system record can be checked. These documents and steps must match the scope and duration of the inspection.

A business may refuse admission if the order is defective or no copy is delivered, the competent authority has not been notified, the inspector lacks special identification, or the required inspection details have not been entered. The refusal should be recorded in writing, identifying the particular missing basis, with proof that the Business Ombudsman, Chamber of Commerce and Industry or prosecutor’s office was notified.

From 1 August 2026, an inspector registers the inspection by scanning the “Biznes himoya” QR code through the mobile application. If the information is not entered, the entrepreneur may refuse entry to the public official. An inspection conducted without registration, supporting documents in the system or special identification is treated as unlawful.

What actions inspectors may take

The extent of an inspector’s authority depends on the type of inspection. Within the Tax Code, a tax authority may request documents, conduct an inspection and inventory, seize documents and electronic media, take photographs and video, obtain explanations, involve an interpreter or expert, and apply collection measures. This general list of powers (Article 26 of the Tax Code) does not override the special restrictions governing desk inspections.

To enter business premises, inspectors must show official identification and the order. A dwelling may be entered against its occupants’ wishes only in a case authorised by law or under a court order (Article 144 of the Tax Code). An inspection of premises, documents and objects is conducted with video recording (Article 145 of the Tax Code), or with witnesses if recording is impossible, and a protocol is prepared.

Documents requested from the inspected person must be submitted within five days (Article 146 of the Tax Code). If that is impossible, the taxpayer must explain the reasons and proposed delivery date in writing on the day after the request. Previously submitted documents may not be requested again, except for returned originals or documents lost by the authority through force majeure. Documents may also be requested from a counterparty, which likewise replies within five days (Article 147 of the Tax Code) or confirms that it does not have them.

Seizure requires a reasoned resolution (Article 148 of the Tax Code), may not take place at night and is conducted in the presence of witnesses. Objects unrelated to the inspection may not be seized. Everything taken is listed in a protocol, and a copy is delivered to the taxpayer.

If an expert examination is appointed, the taxpayer is shown the resolution. The taxpayer may challenge an expert, propose another expert and questions, and, with the inspector’s permission, attend the examination (Article 150 of the Tax Code). A video recording of a control action must be continuous, and a copy must be provided (Article 153 of the Tax Code) after the event.

What rights a taxpayer has

A taxpayer may participate personally and through a representative. The following items from the broader list of rights (Article 21 of the Tax Code) are particularly important during an inspection:

• to attend a field inspection or audit on its premises;
• to review materials and receive reports;
• to provide explanations on compliance with tax legislation;
• to refuse demands that do not comply with tax legislation;
• to participate when the inspection materials are considered;
• to appeal decisions, actions or omissions;
• to claim compensation for losses;
• to require protection of tax secrecy.

A tax-consulting organisation or another authorised person may act as representative. A legal entity’s representative acts under a contract or power of attorney (Article 24 of the Tax Code). The manager’s personal participation does not remove the right to representation.

At the same time, a taxpayer must not obstruct a lawful inspection, must provide access to documents and electronic data, and must comply with lawful demands. The tax authority must explain rights and duties, communicate the results, preserve tax secrecy and, on request, prepare a reconciliation statement (Article 27 of the Tax Code).

Documents or information obtained unlawfully may not be used (Article 135 of the Tax Code) as grounds for liability. Losses unlawfully caused by an inspection are subject to full compensation (Article 155 of the Tax Code).

How results and objections are documented

A tax audit ends with a report. It contains information about the inspected person and inspectors, the order, documents, period, taxes, control actions, identified breach and conclusions. A copy must be delivered within three days (Article 156 of the Tax Code). A signature confirms receipt, not agreement with the findings.

Objections to an audit report may be submitted with supporting documents within ten days after receipt. An audit report, and field-inspection materials identifying a breach, are considered after ten but no later than fifteen days after the report was prepared. The taxpayer receives at least two working days’ notice (Article 158 of the Tax Code) of the hearing. It may attend personally or through a representative, and late supporting documents may still be considered.

The head or deputy head then decides whether to assess additional tax and interest and whether to impose liability. The decision must address the facts, evidence, defence arguments, rules applied and appeal procedure (Article 159 of the Tax Code). It is normally delivered within two days and takes effect after one month (Article 160 of the Tax Code), unless an appeal is filed.

What may follow a tax inspection

A decision may result in an additional tax assessment, interest and a financial penalty. To secure enforcement, the tax authority may first prohibit disposal of property and, if its value does not cover the obligation, suspend bank transactions up to the unsecured amount. These security measures (Article 161 of the Tax Code) may be replaced by a bank guarantee, pledge or surety.

Separately, the tax authority may suspend account transactions for up to 10 days (Article 111 of the Tax Code); a longer suspension requires a court decision. Grounds include a failure to submit a return, reply to a demand or provide requested documents, obstruction of access, and absence from the registered address.

Non-payment or underpayment caused by incorrect calculation or other unlawful acts generally carries a penalty of 20% (Article 224 of the Tax Code) of the unpaid amount. The general time limit for tax liability is three years (Article 217 of the Tax Code); time is suspended where active obstruction becomes an insurmountable impediment to the inspection.

Example. Assume an inspection establishes an underpayment of UZS 100,000,000 and the general 20% rate applies. The penalty is UZS 100,000,000 × 20% = UZS 20,000,000. If the taxpayer admits fault and voluntarily pays the penalty within ten days (Article 218 of the Tax Code), it is halved: UZS 20,000,000 / 2 = UZS 10,000,000. Tax and late-payment interest are calculated separately.

This section covers only consequences directly connected to the inspection procedure. The separate article on tax offences and sanctions discusses the elements of offences and financial, administrative and criminal liability. It is relevant once the report assigns a specific legal characterisation.

How to appeal tax-inspection results

An appeal to a higher tax authority or a court suspends enforcement of the challenged decision, collection of additional assessments and application of financial penalties. The authority whose decision is challenged must be notified and given proof of filing. This suspension of enforcement (Article 231 of the Tax Code) lasts until the higher authority decides the appeal or the court judgment takes effect.

A field-inspection or audit decision is appealed through the authority that issued it within one month (Article 232 of the Tax Code) from the day the person knew or should have known that its rights were breached. That authority forwards the appeal and materials to the higher authority within three days. A deadline missed for a valid reason may be restored.

An appeal may be written or electronic. It must contain five elements (Article 233 of the Tax Code):

• details of the applicant;
• the challenged instrument, action or omission;
• the name of the relevant tax authority;
• the grounds on which rights are considered breached;
• the applicant’s requests.

A representative must attach evidence of authority. The higher authority normally decides an appeal against an audit decision within one month and another appeal within fifteen days. Either period may be extended by 15 days (Article 235 of the Tax Code); the decision is sent to the applicant within three days.

How to prepare for a tax inspection

Preparation begins before an inspection order. Accounting documentation includes primary documents and registers (Article 76 of the Tax Code), as well as other documents underlying taxable items, tax calculations and reporting. Each line of a return should be linked in advance to a register, invoice, contract, acceptance certificate, delivery note and payment record.

If an error understates tax, an amended return should be filed before the company learns that the tax authority has detected it or that an audit has been assigned. Relief from liability is possible on two conditions (Article 83 of the Tax Code): the return is filed before that point, and the missing tax and interest are paid before filing. Once an audit starts, returns for the period under review may not be amended.

After receiving a notice or order, a company should:

• record the date of receipt through its online account or by post;
• verify the type, grounds, scope, period and duration of the inspection;
• check the inspectors, registration and documents in “Yagona davlat nazorati”;
• appoint a responsible employee and document the representative’s authority;
• inventory every document supplied and retain proof of transmission;
• notify the authority in writing on the following day if the five-day document deadline is objectively impossible;
• distinguish substantive explanations from objections to the report and an appeal against the decision.

What changed in 2025–2026

• Decree UP-138 of 19 August 2025 made a mobile video camera mandatory for field tax inspections from 1 January 2026; an inspection without one is unlawful.
• Decree UP-95 of 19 May 2026 abolished from 1 July 2026 the duty to submit an amended return or explanation following pre-audit analysis, and gave medium-risk taxpayers one month to remedy shortcomings without an inspection.
• Decree UP-63 of 17 April 2026 launched an updated “Yagona davlat nazorati” system from 1 July 2026 and inspection registration through the “Biznes himoya” QR code from 1 August.
• Decree PF-175 of 27 August 2026 introduced a three-year moratorium on inspections of small businesses from 28 August 2026. Exceptions cover criminal cases, effects on health, compliance with labour legislation, citizen complaints, VAT refunds and liquidation.

What will change from 2027

From 1 January 2027 through 31 December 2028, medium and large businesses will be able to commission an initiative audit from an audit organisation. A tax audit normally will not be conducted for a period covered by its opinion; if identified errors are corrected within 30 days, no financial penalty will be imposed. Breaches not covered by the opinion remain an exception.

From the same date, any repeat business inspection within a year will require permission from the Business Ombudsman, except for a desk inspection. A “warning for the first error” rule will also apply: if a first breach has caused no harm to life, health or another person’s property, the entrepreneur will first receive ten days to remedy it.

What a taxpayer should do now

Check the online account every day, because an electronic document is deemed received no later than the third day after dispatch. Maintain one log of notices, demands, replies, transferred files and protocols. Before admitting an inspector, reconcile the QR registration, order, programme, special identification, purpose, period and inspection team.

During the inspection, supply documents against an inventory, record every control action and request a copy of the video. After the report, separate factual errors from legal characterisation, prepare documented objections and do not miss the appeal deadline. This sequence protects the company’s rights without obstructing a lawful inspection.

Frequently asked questions

How long does a tax inspection take?

The time limit depends on the type. A desk inspection lasts no more than 60 days and a field inspection no more than 10 days. A tax audit is normally limited to 30 days, but it may be extended to two months, or exceptionally three months; the overall limit is six months. A remote digital-labelling inspection takes no more than five days. Each type has its own counting rules, so the date of the order, delivery of a report or signing of a report may have independent significance.

Can the tax authority inspect the same period again?

A repeat desk inspection of the same taxes for the same period and a repeat tax audit of the same taxes and period are normally prohibited. New circumstances that the tax authority could not consider during the first inspection are an exception. From 1 January 2027, another business inspection within the same year will additionally require permission from the Business Ombudsman, except for a desk inspection.

May a business refuse to admit a tax inspector?

Yes, but only for a specific procedural defect: for example, the inspection is not registered, supporting documents have not been entered into the system, the order is defective or not delivered, or the inspector lacks special identification. From August 2026, registration through the “Biznes himoya” QR code also matters. The refusal should be recorded in writing and tied to the missing document or registration, without obstructing the inspection after the defect is cured.

What should be signed if the company disagrees with the report?

A signature on a tax-audit report confirms receipt, not agreement with the findings. Record the date of receipt, obtain the company’s copy, and prepare written objections with supporting documents. The deadline for objections to an audit report is ten days. Failure to submit written objections does not remove the right to explain the position when the materials are considered, but a written submission helps connect every argument to its evidence.

Does an appeal suspend collection?

Yes. An appeal to a higher tax authority or court suspends enforcement of the challenged decision, collection of additionally assessed tax and application of financial penalties. The taxpayer must notify the authority whose decision is challenged and attach proof of filing. A field-inspection or audit decision is appealed through that authority within one month from the day the person knew or should have known that its rights were breached.