Viktoriya Sleta viktoriya.sleta@rsp-i.com On 27 July 2026, the Law of the Republic of Uzbekistan No. ZRU-1161 "On Compensation for Damage Caused by Unlawful Decisions, Actions or Inaction of a State Authority or Its Official" was adopted. The Law is aimed at protecting the rights of individuals and legal entities and introduces a unified mechanism for compensating both material and moral damage. Payments will be made from territorial compensation funds established under the Council of Ministers of the Republic of Karakalpakstan and the khokimiyats of the regions and the city of Tashkent. The amounts paid will subsequently be recovered from the responsible party through a right of recourse. Compensation covers actual damage, lost profits, and moral harm — the latter only for individuals. Compensation is not granted automatically: a court must first establish the unlawfulness of the authority's actions and determine the extent of the damage, after which payment is made from the compensation fund. The Law also amends a number of legislative acts governing the enforcement of court decisions in such cases. The Law enters into force on 28 January 2027. #Uzbekistan #Legal

Viktoriya Sleta viktoriya.sleta@rsp-i.com Presidential Decree No. UP-160 dated August 14, 2026, approves the “Justice – 2030” Strategy, which provides for the reform of the judicial system through 2030. Starting July 1, 2027, the creation of interregional courts is planned, which will be vested with authority to review cases decided by regional and equivalent courts. Simultaneously, preparations are underway to redistribute the authority to review judicial acts among judicial instances. The corresponding amendments are to be codified in legislation upon the Supreme Court's preparation of the relevant draft laws. Specific measures are aimed directly at simplifying access to court. It is envisaged to eliminate the practice of returning statements of claim on the grounds of lack of jurisdiction: the statement of claim must be transferred by the court to the competent court. Furthermore, it is proposed to admit statements containing minor formal defects, with their subsequent rectification assisted by the court. For the resolution of economic disputes, effective January 1, 2028, it is planned to implement the “Proactive Case Management” standard, which imposes a duty on the court to take measures to eliminate non-substantial formal defects during case proceedings. This is expected to facilitate more prompt dispute resolution and reduce procedural costs. The Strategy also provides for increasing the transparency of judicial practice. Effective August 1, 2027, the open publication and regular updating of rulings of the Presidium of the Supreme Court — which shape uniform judicial practice — is planned within the framework of the "Precedents" registry. Digital judicial services will also be expanded: by the end of 2027, the enhancement of the Supreme Court portal “my.sud.uz”, the simplification of procedural document drafting, and the expansion of search capabilities for judicial acts are envisaged. The Decree entered into force on August 15, 2026. #Uzbekistan #Legal

Joerg Gulden joerg.gulden@rsp-i.com July 2026 brought a number of important decisions by the Federal Fiscal Court and new administrative guidelines from the Federal Ministry of Finance, impacting tax practice. The following overview categorizes the key publications by tax type. VAT Input tax deduction from legal costs The Federal Fiscal Court (BFH) confirms the deduction of input tax for legal services that serve to enforce a claim, provided that the claim arises from an intended or actually carried out entrepreneurial activity. Source: Federal Fiscal Court (BFH), Judgment VR 15/24 Input tax apportionment and supply of goods: two approved revisions In two rulings, the Federal Fiscal Court (BFH) granted leave to appeal without yet deciding the merits of the cases. VB 28/25 concerns the apportionment of input tax in the case of a building extension with newly constructed, tax-exempt areas. VB 43/25 concerns the VAT classification of beverage production where the recipient of the service procures the water himself. Sources: Federal Fiscal Court (BFH), Decision VB 28/25 | Federal Fiscal Court (BFH), Decision VB 43/25 VAT conversion rates The Federal Ministry of Finance (BMF) published the updated overview of the conversion rates to be applied pursuant to Section 16 Paragraph 6 of the German VAT Act (UStG) in July 2026. Source: BMF letter dated July 1, 2026 Corporate income tax and trade tax Corporate income tax and trade tax Municipal tax consolidation If a subsidiary within a group of companies operates a business that qualifies for preferential tax treatment under Section 8 Paragraph 7 of the German Corporation Tax Act (KStG) in terms of sustained losses, the determination of the division's profitability must be carried out at the parent company level using the gross method. Losses in the division in question cannot be offset against investment income outside of that division. Source: Federal Fiscal Court (BFH), Judgment IR 5/23 One or more commercial enterprises When a sole proprietor engages in multiple activities, the distinction between a single business and several independent businesses is determined by the similarity of the activities and their economic, organizational, and financial relationship. Source: Federal Fiscal Court (BFH), Judgment XR 8/23 Income tax Part-time tax consulting and profit motive A prolonged period of losses does not necessarily preclude tax deductibility. A plausible plan to expand business activities after retirement and offset the total losses incurred to date can be decisive. Source: Federal Fiscal Court (BFH), Judgment VIII R 26/23 Private sales transactions For the calculation of the ten-year period stipulated in Section 23 of the German Income Tax Act (EStG), the decisive factor is generally the date of the contractual obligations. The transfer of beneficial ownership is irrelevant in this respect. Source: Federal Fiscal Court (BFH), Decision IX B 24/26 Refund of wage tax in cases covered by double taxation agreements An employee cannot base a claim for reimbursement analogously on Section 50d Paragraph 1 Sentence 2 of the former Income Tax Act (EStG a.F.) if the employer has wrongfully withheld wage tax. The Federal Fiscal Court (BFH) changed its jurisprudence and simultaneously established a protection of legitimate expectations for reimbursement claims already submitted. Source: Federal Fiscal Court (BFH), Judgment VI R 12/24 Cross-border commuters under the Double Taxation Agreement with Switzerland Whether a work-related reason for non-return exists must be assessed based on the specific working circumstances. The distance between the workplace and residence is not the sole determining factor. Sources: Federal Fiscal Court (BFH), Judgment VI R 31/24 | Federal Fiscal Court (BFH), Judgment VI R 14/24 Working on ships flying the German flag According to a revised administrative interpretation, work performed on the high seas is no longer considered to be carried out domestically solely because of the German flag. This new interpretation will be applied for the first time to tax assessment and payroll periods beginning after December 31, 2026. Source: BMF letter dated July 6, 2026 Electric and hybrid electric vehicles The Federal Ministry of Finance (BMF) adapted its administrative instructions on the private use of company electric and hybrid electric vehicles to the flat-rate electricity price introduced on January 1, 2026. Source: BMF letter dated July 21, 2026 Conversion tax law Application for book value in the merger deed The application for book value required for a merger can already be included in the notarized merger deed when it is submitted to the tax office. The Federal Fiscal Court (BFH) considers Section 4 Paragraph 6 Sentence 6 Alternative 2 of the German Reorganization Tax Act (UmwStG) to be constitutional. Source: Federal Fiscal Court (BFH), Judgment IV R 3/23 Tax Code and Procedural Law Fees for binding information Multiple requests for binding rulings can trigger multiple fees. The determining factor is whether a single, unified set of planned circumstances exists. Following the ruling, the fees are not subject to the statute of limitations for tax assessments. Source: Federal Fiscal Court (BFH), Judgment II R 38/23 Liability for involvement in tax evasion According to the decision, the special suspension of the limitation period under Section 191 Paragraph 5 Sentence 2 of the German Fiscal Code (AO) does not apply in favor of a party who has merely provided assistance or instigated the act. Source: Federal Fiscal Court (BFH), Judgment VII R 18/24 Estimation methods and open cash register The Federal Fiscal Court (BFH) emphasizes the priority of more precise estimation methods. An internal business comparison is generally more meaningful than an external comparison. In the case of an open cash register, the lack of daily cash balance records constitutes a formal deficiency and can justify an estimation. Sources: Federal Fiscal Court (BFH), Judgment XR 14/24 | Federal Fiscal Court (BFH), Judgment XR 19/23 Technical rejection of electronic submissions The Federal Fiscal Court (BFH) granted leave to appeal on the procedural question of how to challenge the technical rejection of an electronically required submission. A decision on the merits has not yet been issued. Source: Federal Fiscal Court (BFH), Decision VB 59/25 Amendment to the application decree for the Tax Code The Federal Ministry of Finance (BMF) amended the administrative guidelines for Sections 51, 52, 53, 55, 56, 57, 64, 65, 66 and 67a of the German Fiscal Code (AO). The amendments primarily concern the law governing non-profit organizations, including the use of funds, loss compensation, participations of non-profit entities, and various monetary limits. Source: BMF letter dated July 2, 2026 legislation Child benefit without application On July 9, 2026, the German Bundestag adopted the government's draft bill, which had been amended during parliamentary deliberations. The plan initially provides for automatic child benefit payments starting with the second child, beginning in March 2027. Source: German Bundestag, resolution of July 9, 2026 Double taxation agreements Updated German negotiating basis The German negotiating basis for double taxation agreements has been updated. It takes into account, in particular, the 2017 OECD Model Tax Convention, the results of the BEPS project, and interim changes to domestic tax law. Source: Federal Ministry of Finance, negotiating basis 2026 Suspension of the Germany-Russia Double Taxation Agreement According to the official German notification, Germany notified the Russian Federation on June 30, 2026, of the suspension of the agreement of May 29, 1996, and its protocol, effective January 1, 2027. The list of sources evaluated here does not contain any official Russian sources; therefore, this article makes no statement regarding the Russian legal interpretation or implementation. Source: BMF press release of July 9, 2026 #Germany #Tax

Valeria Nesterova valeria.nestrova@rsp.i.com Starting August 1, 2025, stock corporations (AO) and limited liability companies (OOO) can again have a company with only one shareholder (partner) that only has one shareholder or partner. This finally puts an end to the long-standing ban on "matryoshka companies" and the discussion about extending this regulation to foreign shareholders and participants in Russian commercial companies. Corresponding amendments have been incorporated into the Civil Code of the Russian Federation, Federal Law No. 208-FZ of December 26, 1995, "On Joint-Stock Companies," and Federal Law No. 14-FZ of February 8, 1998, "On Limited Liability Companies." However, the legislature has left some room for maneuver. Other federal laws may reintroduce the ban or extend it to certain categories or specific companies.   In addition, as of August 1, 2025, the question of whether the resolution of the sole shareholder of an AO must be certified will also be finally clarified. The new version of Article 47(6) of Federal Law No. 208-FZ of December 26, 1995, "On Joint-Stock Companies," stipulates that resolutions adopted by the sole shareholder of an AO who holds all voting rights do not generally require certification by a registrar or notary public. Deviating provisions may be laid down in the articles of association of the joint stock company.   #Russia #Legal

Jens Jungmann jens.jungmann@rsp-i.com The Kazakh Ministry of National Economy submitted a package of amendments to the draft Tax Code to the Mazhilis, the lower house of Parliament. The proposed changes aim to enhance tax administration and include a significant increase in the value-added tax (VAT) rate from 12% to 16%. According to the ministry’s press service, a reduced VAT rate of 10% will apply to specific industries. Additionally, the amendments propose lowering the threshold for mandatory VAT registration from 78.6 million tenge (approximately US$157,350) to 15 million tenge (approximately US$30,028). The revisions also introduce limitations on the special tax regime for simplified declarations, restricting its application solely to the business-to-consumer (B2C) sector. If approved by the Mazhilis, the amendments will proceed to the Senate for further consideration. #Kazakhstan #Tax

Patrick Pohlitt patrick.pohlit@rsp-i.com According to the Ministry of Finance, the Embassy of the Kingdom of Sweden has sent a note on the full suspension of the Convention on the Avoidance of Double Taxation between the Russian Federation and Sweden. The suspension will come into force on February 1, 2025. Since the decision of the Swedish regulator does not provide for exceptions for certain articles in comparison with the Decree of the President of the Russian Federation from 08.08.2023 № 585, from 2025 residents of Sweden will not be able to offset tax paid in Russia, and the mechanism of mutual agreement procedure, as well as officially suspend the exchange of information between the states. #Russia #Tax

Patrick Pohlit patrick.pohlit@rsp-i.com The US custodian Bank of New York Mellon announced that it will open books for the exchange of depositary receipts for shares of Russian companies from August 22, 2024. The procedure will last until September 20, 2024 and will be applied to certificates of Gazprom, RusHydro, Nornickel and others. BNY Mellon decided to convert the depositary receipts due to the inclusion of the National Settlement Depository (NSD) on the U.S. sanctions list and on the basis of General License No. 100. The application requires proof of compliance with the requirements of this license, unchanged beneficial ownership and an account with a Russian depository for the shares to be credited. The current license applies to depository receipts of the following share issuers - Federal Grid Company, - Cherkizovo Group, - Inter RAO UES, - RusHydro, - Surgutneftegaz, - Mosenergo, - MMC Norilsk Nickel, - Enel Russia, - Primorsk Shipping Company, - Gazprom Neft, - Gazprom. At the same time, taking into account the constantly changing circumstances, the Depositary reserves the right to terminate the exchange program at any time before the expiry of the specified period without prior notice. #Russia #Legal

Patrick Pohlit patrick.pohlit@rsp-i.com The US Treasury Department has published an official notice suspending Article 1(4), Articles 5-21 and 23 and the Protocol to the US-Russia Double Taxation Avoidance Agreement of June 17, 1992 by mutual agreement on the US side. The suspension will enter into force on August 16, 2024 and will remain in force until the governments of the contracting states adopt a corresponding decision. Thus, the articles of the Agreement referred to in Decree No. 585 of the President of the Russian Federation of August 8, 2023 are suspended in mirror image. #Russia #Tax

Viktoriya Sleta viktoriya.sleta@rsp-i.com In accordance with the Decree of the President of the Republic of Uzbekistan (Decree No. 80 dated May 24, 2024) new measures aimed at creating additional convenience for citizens and entrepreneurs in obtaining public services are introduced. From July 1, 2024: citizens will be able to undergo identification in the Mobile-ID system at their request when applying for ID-cards and biometric passports for travelling abroad. This service will be provided at public service centers (PSC); data on property rights that have been registered earlier and remain valid will be entered into the state register free of charge. Citizens will also be able to obtain an extract from this register free of charge; transactions involving the transfer of non-residential premises will be able to be formalized at the PSC. The identity of the parties to the transaction will be established by an employee of the PSC, and information on the transaction will be sent immediately to the cadastral authorities for state registration. By the end of 2024: the biometric identification method (Face-ID) will be introduced in the provision of public services, which will allow citizens not to require the provision of identity documents; identification and re-identification of citizens in the Mobile-ID system through the PSC and notary offices will be carried out free of charge. #Uzbekistan #Legal

Viktoriya Sleta viktoriya.sleta@rsp-i.com From 1 May 2024, obtaining writ of execution has become simpler Uzbekistan has simplified the procedure for obtaining writs of execution. Now legal entities can receive and provide writs of execution issued on the basis of judicial acts, as well as decisions and other documents in the framework of enforcement proceedings electronically through the personal cabinet of the taxpayer. This became possible due to the introduction of a new procedure for issuing (sending, providing) writs of execution on the basis of judicial acts in electronic form. In addition, the minimum amount of guaranteed income of citizens, which cannot be foreclosed on debts, has been established. It amounts to 0.5 minimum wage. These changes are aimed at simplifying and accelerating the process of obtaining writs of execution, increasing the transparency and efficiency of the enforcement authorities and protecting the rights and legitimate interests of citizens. The new measures are expected to contribute to: reducing the number of disputes related to enforcement proceedings; increasing the number of court judgements executed in a timely manner; reducing the time needed to recover debts. #Uzbekistan #Legal

Viktoriya Sleta viktoriya.sleta@rsp-i.com From 1 January 2024, individuals registered as individual entrepreneurs in accordance with the legislation of a foreign state and carrying out business activities in the territory of the Republic of Uzbekistan, along with foreign legal entities, are VAT payers, provided that: they realise goods (services) in the territory of the Republic of Uzbekistan; the place of sale of these goods (services) is the territory of the Republic of Uzbekistan. The absence of foreign individual entrepreneurs among VAT payers in Article 237 of the Tax Code of the Republic of Uzbekistan previously led to different taxation conditions for domestic and foreign entrepreneurs. With the introduction of this norm, the same taxation conditions apply for domestic and foreign individual entrepreneurs. #Uzbekistan #Tax

Viktoriya Sleta viktoriya.sleta@rsp-i.com VAT exemption is granted for the sale and import of goods (services) purchased as part of projects, the implementation of which is fully or partially financed by public external debt raised and attracted from international financial institutions (IFIs) and foreign governmental financial organizations (FGFOs) for the development of social sphere and infrastructure: budgetary organizations; state-owned enterprises; legal entities with the state share in the authorized fund (authorized capital) in the amount of 50% and more. The privilege cannot be applied in case if the funds of IFIs and FGFOs for realization of infrastructure projects are refinanced or re-loaned through commercial banks of the Republic of Uzbekistan. It is important to note that the benefit applies to relations arising from November 16, 2023, despite the fact that the Tax Code introduces the benefit from January 1, 2024. The benefit is valid until January 1, 2028. #Tax #Uzbekistan