Article 18. Tax and Customs regime in the territory of the TIFC

1. The tax and customs regime applicable in the territory of the TIFC shall be governed by this Constitutional Law and by TIFC Acts adopted in consultation with the Ministry of Economy and Finance of the Republic of Uzbekistan. The Tax Code of the Republic of Uzbekistan shall apply within the TIFC only to the extent expressly provided by this Constitutional Law or by such TIFC Acts adopted in consultation.

2. Until 1 January 2076, TIFC Bodies and their organisations (being organisations established by, or wholly owned and controlled by, TIFC Bodies) are exempt from income and social taxes subject to compliance with any conditions provided by the TIFC Acts referred to in paragraph 1 of this Article.

3. Until 1 January 2076, Qualified TIFC Participants, except for digital asset exchanges that do not satisfy the economic substance, governance, AML/CFT, counter-proliferation financing, cybersecurity, and other conditions prescribed by TIFC Acts, are exempt from income tax and social taxes in respect of income derived from Financial Services, subject to compliance with any conditions provided by the TIFC Acts referred to in paragraph 1 of this Article and to the requirements set out in this Article.

4. For the purposes of this Article, a “Qualified TIFC Participant” means a TIFC Participant that satisfies all of the following conditions:

1. it maintains adequate economic substance in the TIFC;

2. it derives the relevant income from the provision of Financial Services rendered or exported from the TIFC; and

3. it satisfies such other requirements as may be prescribed by TIFC Acts adopted by the TIFC Authority in consultation with the Ministry of Economy and Finance of the Republic of Uzbekistan.

5. A TIFC Participant that does not satisfy the conditions set out in paragraph 4 of this Article, or that is a digital asset exchange that does not satisfy the economic substance, governance, AML/CFT, counter-proliferation financing, cybersecurity, and other conditions prescribed by TIFC Acts, shall be subject to taxation in accordance with the Tax Code of the Republic of Uzbekistan as applied pursuant to paragraph 1 of this Article, and shall retain the exemption established by paragraph 6 of this Article where the conditions of that paragraph are satisfied.

6. Until 1 January 2076, TIFC Participants shall, subject to compliance with any conditions provided by the TIFC Acts referred to in paragraph 1 of this Article, be exempt from income tax and social tax in respect of income received from Ancillary Services provided within the territory of the TIFC.