Suspension of transactions on a bank account can effectively bring a company’s operations to a standstill: the business becomes unable to make payments to suppliers, carry out ordinary debit transactions, or perform a substantial part of its current obligations. At the same time, the rule that “a bank account may be blocked only by a court order” does not apply in Uzbekistan. However, it is equally incorrect to claim that the tax authority may, in any situation, independently block a business account for ten days. The applicable legal regime is primarily governed by Articles 111–113 of the Tax Code and, from 1 May 2025, also by paragraph 5 of Presidential Resolution No. PP-33 dated 30 January 2025. Part One of Article 111 of the Tax Code provides that the head or deputy head of a tax authority may issue a decision to suspend transactions on a taxpayer’s accounts for a period of no more than ten days. If transactions are to be suspended for more than ten days, the decision must be made by a court upon an application filed by the tax authority. Until the court resolves the matter, the suspension remains in effect. The tax authority’s decision is sent to the bank electronically, while the taxpayer must simultaneously receive a notification through its personal account specifying the reasons for the suspension. This does not mean that the tax authority may block accounts at its discretion. Part Three of Article 111 of the Tax Code establishes specific grounds for applying this measure to legal entities and individual entrepreneurs. Transactions may be suspended if the required reports have not been submitted within ten days after the statutory filing deadline has expired. Accordingly, merely missing the ordinary reporting deadline does not automatically result in an immediate account suspension: Article 111 provides an additional ten-day period. The second ground arises where the taxpayer fails, within the prescribed period, to provide explanations and/or corrections in response to a requirement issued by the tax authority following a desk tax audit, or fails to provide documents requested by the tax authority. For this reason, ignoring a requirement issued by the tax authority is risky even where the taxpayer considers it unfounded. If the company disagrees with the requirement, the legally safer approach is to submit a reasoned response and formally record its objections rather than simply leave the document unanswered. Another ground is obstruction of access by tax officials conducting a tax audit to the taxpayer’s territory or premises, except for residential premises. Article 111 expressly requires the fact of obstruction to be documented in an official report. It is this report that serves as the basis for the subsequent suspension of account transactions. The fourth ground is the absence of a legal entity or individual entrepreneur from the address officially declared by it. In practice, therefore, it is important not only that the company be duly registered, but also that it be able to confirm its actual presence at the registered address, receipt of correspondence, and the existence of a reasonable explanation for any temporary absence. Article 111 of the Tax Code cannot be interpreted in isolation from the subsequent Presidential Resolution No. PP-33 dated 30 January 2025, “On Additional Measures for the Introduction of Modern Mechanisms for Judicial Protection of the Rights of Citizens and Business Entities.” Under paragraph 5 of Resolution No. PP-33, from 1 May 2025 the tax authority suspends transactions on the bank accounts of a business entity where that entity acknowledges the commission of a tax offence. If, however, the business entity does not acknowledge the tax offence and objects to the suspension of account transactions, the matter must be resolved by a court upon an application filed by the tax authority. This is an important safeguard for businesses. At the same time, the difference in wording between the two legal instruments must be taken into account. Article 111 of the Tax Code lists grounds for suspending transactions as a measure securing the performance of tax obligations, whereas Resolution No. PP-33 uses the concept of a “tax offence.” It is therefore incorrect to state that Resolution No. PP-33 simply abolished the entire extrajudicial mechanism established by Article 111. However, it is equally incorrect to disregard Resolution No. PP-33 where the tax authority links the suspension specifically to the commission of a tax offence. The practical significance of this rule is clear: where a business disagrees with the alleged violation, its non-recognition of the offence and its objection to the account suspension should be expressly recorded in writing. The position of the Supreme Court in such cases is specific. Paragraph 34 of Resolution No. 4 of the Plenum of the Supreme Court dated 20 February 2023, “On Certain Issues Concerning the Application of Tax Legislation by Courts,” explains that where a tax authority applies to a court for suspension of account transactions, the court must verify: — whether the grounds provided for in Part Three of Article 111 of the Tax Code actually exist; — whether there is a decision by the head or deputy head of the tax authority suspending transactions for a period not exceeding ten days. Accordingly, judicial proceedings should not be reduced to formal approval of the tax authority’s request. The existence of a statutory ground must be independently examined. Under Part Four of Article 111 of the Tax Code, suspension means that banks must discontinue all debit transactions on all accounts of the taxpayer. Exceptions apply to first-priority payments under civil legislation and to accounts against which enforcement is prohibited by law. The bank is required to comply unconditionally with the tax authority’s decision. Moreover, after receiving a decision of the tax authority or a court order suspending transactions, the bank may not open new accounts, deposits, or savings accounts for that taxpayer, except for special accounts against which enforcement is prohibited by law. Accordingly, simply attempting to open a new settlement account with another bank will not resolve the problem. These mechanisms must be distinguished. Suspension of transactions is governed by Articles 111–113 of the Tax Code and constitutes a security measure. Compulsory collection of an existing tax debt is governed by other provisions, primarily Articles 120–121 of the Tax Code. Under Article 121, if a requirement to repay tax debt is not complied with, the tax authority enforces recovery against the funds of a legal entity or individual entrepreneur by sending an electronic collection order to the bank. Therefore, the existence of a restriction visible in the taxpayer’s personal account or imposed by a bank does not by itself answer the question of what has actually occurred. It is first necessary to identify the legal basis: whether it is a suspension of debit transactions under Article 111 or enforcement of tax debt under Article 121. The appropriate method of legal protection depends on this distinction. Article 112 of the Tax Code establishes precise time limits. If the suspension was caused by failure to submit reports, the decision must be revoked no later than the day following their submission. If the ground was failure to submit documents, explanations, or corrections requested by the tax authority, the suspension must be lifted on the day those materials are submitted. If the reason was refusal to allow tax inspectors access, the decision must be revoked no later than the day following the granting of access. If the taxpayer was considered absent from its declared address, the decision must be revoked no later than one day after the tax authority recognises the reasons for the absence as justified. The Tax Code expressly includes, among such reasons, registration with another tax authority, a technical error, and other similar circumstances. After adopting a decision to lift the suspension, the tax authority must send that decision to the bank electronically no later than the following day. Article 112 of the Tax Code provides not only for the lifting of an unlawful restriction but also for financial liability of the tax authority. If the tax authority violates the deadline for lifting the suspension or the deadline for sending the relevant decision to the bank, interest accrues on the funds that were subject to the suspension for each calendar day of the delay. The same rule applies where the original decision to suspend transactions was unlawful. In such a case, interest accrues from the date on which the bank receives the suspension decision through and including the date on which it receives the decision lifting the suspension. The applicable interest rate is equal to the refinancing rate of the Central Bank in force during the relevant period. This is an important statutory remedy that businesses use considerably less frequently than the appeal mechanism itself. Where an account has been unlawfully blocked, the issue should therefore concern not only restoration of account operations but also the application of Parts Six through Eight of Article 112 of the Tax Code. Yes. Article 230 of the Tax Code grants every person the right to challenge non-regulatory acts of tax authorities, as well as actions or omissions of their officials, where such acts, actions, or omissions violate that person’s rights. Article 231 provides for the possibility of filing a complaint with a higher tax authority or bringing the matter before a court. Moreover, Part Three of Article 231 establishes that filing a complaint suspends the execution of the challenged decision or action, including recovery of additionally assessed taxes and application of financial sanctions, until the complaint has been resolved or the relevant court decision has entered into legal force. Where the subject of the challenge is specifically an account suspension, the decision must be precisely identified by reference to its date, number, legal ground, duration, and consequences. The mere submission of a complaint, without proper confirmation of its receipt and without resolving the issue of its actual implementation by the bank, should not be regarded as sufficient legal protection. The first question is: what document constitutes the legal basis for the restriction — a decision under Article 111 of the Tax Code, a court order, or a collection order under Article 121? The second question is whether one of the four grounds listed in Part Three of Article 111 actually exists. The third is when exactly that ground arose and whether the statutory time limits were observed. The fourth is whether, where the tax authority relies on the commission of a tax offence, the taxpayer acknowledged that offence and whether a written objection to the account suspension exists for the purposes of paragraph 5 of Resolution No. PP-33. The fifth is whether the ground for the suspension has already been eliminated and whether the deadline established by Article 112 for lifting the suspension has expired. The sixth is whether the taxpayer has already acquired a right to interest as a result of an unlawful or excessively prolonged suspension of transactions. This sequence makes it possible to determine whether the business should seek immediate administrative lifting of the restriction, apply to a court, or use both remedies simultaneously. The tax authority does indeed have statutory powers to suspend transactions on business bank accounts. However, those powers are not unconditional. Articles 111–113 of the Tax Code establish a closed list of grounds, procedural time limits, the procedure for lifting the suspension, and the obligation of the tax authority to pay interest where the restriction was unlawful. From 1 May 2025, paragraph 5 of Resolution No. PP-33 has additional significance: where a business entity does not acknowledge a tax offence and objects to suspension of its bank account on that ground, the matter must be resolved by a court. Accordingly, when an account is blocked, the key task for a business is not simply to determine “when the account will be unblocked,” but to establish the specific legal basis for the restriction and whether the tax authority has complied with the entire statutory procedure for imposing it. Prepared as of 29 August 2026.Blocking a Bank Account by the Tax Authorities: When It Is Possible Without a Court Order and How to Protect Your RightsLICT BETWEEN COMPANY PARTICIPANTS
What Does Article 111 of the Tax Code Provide?
1. Failure to Submit Tax or Financial Reports
2. Failure to Comply with a Requirement Following a Desk Tax Audit
3. Obstruction of Tax Inspectors During an Audit
4. The Taxpayer Is Absent from Its Declared Address
What Changed from 1 May 2025?
What Does the Court Examine?
What Does an Account Suspension Actually Mean?
Account Suspension and Recovery of Tax Debt Are Not the Same
When Must the Tax Authority Unblock the Account?
What Happens in the Event of an Unlawful Account Suspension?
Can the Tax Authority’s Decision Be Challenged?
What Should Be Checked During the First Hours After an Account Is Blocked?
Conclusion
Legal Framework
