On August 20, the president signed a Constitutional Law on the International Center for Digital Technologies Enterprise Uzbekistan. The country now has two special jurisdictions: TMFC — for the financial sector, Enterprise — for technology business. Both centers are planned to launch in 2027, and together they should attract $20−25 billion.

Key differences

As noted by Vladimir Sokolov, head of the legal practice at PwC Uzbekistan, throughout the entire history of independent Uzbekistan, only slightly more than ten constitutional laws have been adopted, including the Constitution itself. The new documents are placed on par with them — this demonstrates the scale of the initiatives.

  • Profile: TMFC — banking, capital markets, insurance, Islamic finance, fintech, digital assets. Enterprise — startups, AI, R&D, GameDev, data processing, intellectual property;
  • Location: TMFC requires a physical office in Tashkent City, Enterprise allows virtual offices and remote participation;
  • Regime duration: until 2076 for TMFC versus 2100 for Enterprise;
  • Benefit stability: TMFC provides for review — the first within 10 years, then every 5 years. The Enterprise law explicitly prohibits worsening conditions or early termination of preferences;
  • Visas: up to 5 years in TMFC, up to 3 years in Enterprise.

What the centers have in common — the Tashkent International Commercial Court and the ability to operate under English law. Only TMFC has its own financial regulator.

It's not about taxes

Umed Rakhimov, head of Stanbase.tech, believes that the focus on zero rates misses the main point. Enterprise solves a different problem: where it is legally convenient for an international investor to invest in Uzbek technology business.

«Imagine an American venture fund that wants to invest $3 million in an Uzbek AI startup. The fund looks not only at the product», — explains the expert. The investor is interested in where the company is registered, how rights and IP are formalized, which court will consider the dispute, and whether this system is understandable to an international lawyer.

This is precisely why DIFC exists in the UAE and AFCA in Kazakhstan: their value lies not in taxes, but in the predictability of corporate law.

Practical scenario

If local legislation does not provide the tools familiar to venture capital, the company creates a holding in another jurisdiction. Enterprise allows building a structure within the country — with elements of English law, a specialized court, and a regulatory sandbox for up to 12 months.

«I would view Enterprise not as a place where you can pay less taxes, but as a place where international tech businesses are being made legally clearer and safer to operate from Uzbekistan», — Rakhimov concludes.

Tax conditions

Enterprise maintains three taxes — VAT, corporate income tax, and personal income tax:

  • profit is exempted for priority areas within the center;
  • VAT — zero rate within the center and for exports;
  • Personal income tax: foreign highly qualified specialists are fully exempt, other foreigners pay 12%, Uzbek citizens pay 7.5%;
  • investors are exempt from dividend tax and investment income tax within the regime.

In TMFC, qualified participants are exempt from corporate income tax and social tax. The exception is international groups with revenue exceeding €750 million, to which the minimum tax under Pillar 2 rules applies.

More than just a free trade zone

Iroda Sadikova, partner at Yakubovs Legal Consulting, emphasizes a fundamental difference from ordinary free economic zones: there, a company receives benefits but remains within national legislation.

Here, the territory becomes a boundary within which its own regulatory, registration, and dispute resolution rules apply. A striking example is labor law: unless Enterprise decides otherwise, the general labor legislation of the republic does not apply, and the center has the right to establish special employment conditions and payment systems.

The «everything not prohibited is allowed» model

The expert separately highlights Article 74 of the law, which guarantees freedom of activity and research in artificial intelligence. Restrictions are prohibited, except for the protection of individual rights, public safety, and international obligations.

Instead of the traditional «only what is directly permitted by law is allowed» model, the opposite is forming: activity is free, and restrictions require special legal basis. For rapidly developing technologies, this is a fundamental difference.

What remains unclear

The criteria for distinguishing between centers have not yet been established. Companies «in between» — fintech, payment services, crypto exchanges, bank outsourcing — could potentially choose the appropriate regime themselves.

An important practical condition: benefits are granted only to participants with real economic presence — with employees, functions, and actual decision-making on site. Formal registration is not sufficient.

For the capital market, the launch of TMFC means the emergence of new infrastructure for issuers and investors. How this will affect the local platform, where investors today track share prices of a narrow circle of companies, will be shown by practice in applying both laws.

This material is for informational purposes and is not an investment recommendation.