US Company Formation from Uzbekistan (2026): US LLC or C-Corp, the Soviet-Era Tax Treaty, Uzbek CFC Rules, IT Park and Banking

Uzbekistan has opened up quickly since 2017. Currency conversion was freed, foreign accounts became ordinary, and IT Park grew into a hub of more than a thousand technology companies that sell services abroad. Developers in Tashkent, Samarkand and Fergana now work for American start-ups. Uzbek outsourcing firms bid for US contracts, and a growing number of founders want a US company for clients, payments and investors.

A US company can be formed from Uzbekistan entirely remotely. Three points shape the decision:

• The tax treaty. The USA still applies its 1973 treaty with the Soviet Union to Uzbekistan. It removes US tax on interest and royalties but does nothing for dividends.
• Uzbek CFC rules. In force since 2022, they can tax undistributed profits of a foreign company an Uzbek resident controls.
• Bank scrutiny. It is higher than for most countries, because Central Asia sits next to the sanctions on Russia.

This guide covers each, then US LLC formation and US C-Corp formation.

In short: Uzbek citizens and residents can own 100% of a US LLC or C-Corporation, formed remotely. Uzbekistan taxes residents' income at a flat 12%, and dividends at 5%. Its CFC rules, in force since 1 January 2022, apply to residents who control foreign companies and can tax their undistributed profits. The 1973 US–USSR treaty, still applied by the USA to Uzbekistan, generally exempts interest and royalties from US withholding but does not reduce the 30% on dividends. A single-member LLC with no US operations usually pays no US income tax and no withholding. With UCB, a Wyoming LLC with EIN is $249 and a Delaware corporation with EIN is $358, all-in.

Who can form a US company from Uzbekistan

US states set no nationality or residence requirement. An Uzbek citizen, a foreign national living in Uzbekistan, an Uzbek company (an MChJ or OOO) and an IT Park resident can each own a US company outright. An individual can be its sole manager or director. No US visa, SSN or US address is needed, and no trip. The company needs a registered agent in its state, which is included for the first year in every UCB formation (see registered agent explained), and an EIN from the IRS, which needs no SSN or ITIN (see EIN for non-residents).

For identity, use your biometric passport. The ID card is not accepted by US banks on its own. Uzbek names are transliterated in several ways (for example Shukhrat, Shuhrat, Shuxrat), so use the spelling in your passport everywhere. For proof of address, a utility bill or bank statement with an English translation.

The treaty the USA still applies

Uzbekistan has never signed a modern income tax treaty with the USA. Instead, the USA treats the 1973 income tax convention with the Soviet Union as still in force with several former Soviet republics, Uzbekistan among them. It is an unusual treaty:

• Dividends. The treaty contains no dividend article, so US dividends to Uzbekistan are withheld at the full 30%.
• Interest and royalties. Paid from the USA to a resident of Uzbekistan, these are generally exempt from US withholding under the treaty.
• Business profits. These are taxable in the USA only through a permanent establishment there.

For an Uzbek owner, this pushes in one direction: a US corporation that pays dividends to Uzbekistan is expensive, while royalties and interest can move without US withholding. An Uzbek company that licenses software or a brand to its US subsidiary, or lends to it, can receive royalties or interest free of US withholding. The amounts must be at arm's length, documented and actually paid for real IP or real loans. US anti-avoidance rules still apply, and so does the Uzbek view of the transaction.

Claim treaty benefits with Form W-8BEN (individuals) or W-8BEN-E (companies). See W-8BEN-E vs W-8BEN.

How Uzbekistan taxes a US company and its owner

Uzbekistan taxes resident individuals on worldwide income:

• Personal income tax is a flat 12%.
• Dividends are taxed at 5%.
• Companies pay corporate income tax at 15% (with different rates for some sectors).
• Foreign tax paid on the same income is generally creditable, up to the Uzbek tax.

CFC rules. Since 1 January 2022, Uzbek residents, both individuals and companies, who own or control a foreign company must report it, and its undistributed profits can be taxed in their hands. The rules target foreign companies in low-tax or preferential regimes. A disregarded US LLC paying no US tax at all is the obvious case. A US C-Corporation paying 21% federal tax is much less likely to be caught. Exemptions and thresholds apply, and the regime has been refined since it started, so confirm the current rules with an Uzbek tax adviser.

IT Park. IT Park residents enjoy tax incentives for qualifying IT activities and export of IT services, including exemptions from several company-level taxes and a reduced personal income tax on employees' salaries. Many Uzbek software firms are IT Park residents. For them, the usual structure is an IT Park company that does the work and earns the incentive, with a US company that contracts with US clients.

US LLC formation from Uzbekistan

The US side

A single-member LLC owned by a non-resident is disregarded for US federal income tax. With no US office, US employees or US agents who conclude contracts, its income is generally not effectively connected with a US trade or business, so no federal income tax is due (see effectively connected income explained). Distributions are not US dividends, so the treaty's missing dividend article does not matter. The LLC files Form 5472 with a pro forma Form 1120 every year, and missing it carries a $25,000 penalty (see Form 5472 explained).

The Uzbek side

For an individual resident, the LLC is a foreign company under Uzbek CFC rules. Because it pays no US tax, its profits can be taxed in your hands each year, whether or not you distribute them. For an IT Park company that owns the LLC, the question is how to price the work between them. The Uzbek company does the work and should earn a market fee for it. The LLC's margin should reflect only what it actually does.

A som example

These are illustrative figures, not a client case, at UZS 12,500 to the dollar.

A Tashkent IT Park company with 30 developers builds mobile apps for clients in the USA. US clients want to sign with a US company, so the Uzbek company forms a Wyoming LLC as its contracting subsidiary.

In 2026 the LLC bills clients US$900,000 and pays the Uzbek company US$820,000 under a development agreement, about UZS 10.25 billion. That counts as IT services export revenue, which benefits from IT Park's incentives. The LLC keeps US$80,000 for its US costs (legal, insurance, a commissioned sales representative and travel) and a small margin.

In the USA, the LLC has no office or staff, so it pays no federal income tax and files Form 5472 and a pro forma 1120. In Uzbekistan, the company's auditor reviews the intercompany pricing and the CFC position of the LLC's small retained margin.

US C-Corp formation from Uzbekistan

The US side

A C-Corporation pays 21% federal tax on its profits, plus state tax where it does business, and files Form 1120 and Form 5472 every year (see the 21% corporate tax explained and the C-Corp guide for non-residents). Dividends to Uzbekistan are withheld at 30%, because the treaty gives no relief. Profit paid out to Uzbekistan therefore bears about 44.7% US federal tax.

When to choose it

• A US subsidiary with US staff or an office, which must pay US tax on its US profit anyway. It should reinvest rather than pay dividends to Uzbekistan, and can pay royalties or interest to the Uzbek parent where there is real IP or a real loan.
• A start-up raising venture capital, which investors require to be a Delaware C-Corporation, usually with the development team in an Uzbek IT Park subsidiary (see raising US investment as a foreign founder).
• Owners in several countries. A corporation keeps the cap table and taxes clear.

Under Uzbek CFC rules, a C-Corporation paying 21% is much less exposed than a disregarded LLC.

Banking and payments

US banks and fintechs accept Uzbek owners, with enhanced checks. Like Kazakhstan, Uzbekistan is watched by US authorities as a possible route for goods subject to sanctions on Russia. Software and services businesses are treated very differently from companies trading electronics or machinery. What helps:

• A specific business description.
• An English website with real projects.
• Matching transliteration of names across documents.
• A US business address with your own suite number.
• For a subsidiary, the parent's registration documents and IT Park certificate.

See US business bank accounts for non-residents, why banks reject non-resident applications and Stripe for non-residents.

If the US company will buy goods for export to Central Asia, expect US suppliers and freight forwarders to screen end users carefully under US export controls.

Moving money

Since the 2017 currency liberalisation, Uzbek residents and companies convert and transfer foreign currency through banks without the old restrictions. Uzbek companies receiving export revenue from a US contracting company should keep the development agreement and invoices ready for their bank's currency control checks. Individuals sending capital to a new US company send small amounts through an Uzbek bank with the formation documents. Ask your bank what it requires before the transfer.

Which state

• Wyoming for a contracting LLC with no US premises: low yearly costs.
• New Mexico, the cheapest, with no annual report.
• Delaware for a corporation raising investment.
• The state where your US staff or office are, if you have them.

See best state for non-residents and the state selector.

What it costs

State fees and the first-year registered agent are included. See what a US LLC costs every year.

Common mistakes

• Assuming the treaty reduces US dividend withholding. The 1973 treaty has no dividend relief, so it stays at 30%.
• Leaving profits in a disregarded LLC without considering Uzbek CFC rules.
• Over-pricing the US contracting LLC, which leaves too little income in the IT Park company that does the work.
• Paying "royalties" or "interest" without real IP or a real loan behind them.
• Skipping Form 5472 because the LLC owed no US tax.

Frequently asked questions

Can an Uzbek citizen own 100% of a US company? Yes, without visiting the USA or holding a US visa.

Is there a US–Uzbekistan tax treaty? The USA applies the 1973 US–USSR treaty to Uzbekistan. It generally exempts interest and royalties from US withholding, but has no dividend provision, so dividends are withheld at 30%.

Do Uzbek CFC rules apply to my US LLC? They can, if you control it and it pays little or no tax, as a disregarded LLC does. A US corporation paying 21% is much less likely to be caught.

Will my US LLC pay US tax? Usually not, with no US office, staff or agents. It files Form 5472 and a pro forma 1120 every year.

Can an IT Park company own a US company? Yes. A common structure is an IT Park company doing the work and a US company contracting with US clients, with arm's-length pricing between them.

Do I need an ITIN? Not to form the company or obtain its EIN. See what is an ITIN and who needs one.

How UCB can help

We handle US company formation from Uzbekistan remotely: the state filing, EIN, registered agent, US business address and bank application. Each year we file the federal return through our US tax filing service. Your Uzbek adviser handles CFC reporting and Uzbek tax, and we provide the US financial statements they need. See our formation, EIN and bank account package and the Kazakhstan guide for a neighbouring comparison.

Setting up a US company from Uzbekistan? WhatsApp us at +1 315 961 2956 or email enquiries@ucbsolutions.com.