The proposal, published for public consultation by the Tax Committee in June, would require banks to notify tax authorities if an individual receives more than 500 base calculating amounts (currently about UZS 206 million) from other individuals within a single month.
The draft prompted criticism from members of the public, many of whom opposed the proposal on the government's public consultation portal.
The debate intensified after Abrorkhuja Turdaliev, Deputy Chairman of the Central Bank, told Kursiv that the proposed rules conflict with the Constitution.
According to Turdaliev, the proposal could violate constitutional guarantees protecting banking secrecy, encourage a shift toward cash transactions, push money out of the formal banking system and into informal circulation, and contribute to the expansion of the shadow economy.
The Tax Committee later responded, saying it respects the Central Bank's position but insisted the proposal is not intended to introduce mass surveillance of citizens' personal transfers.
Kun.uz spoke with tax consultants Yorqin Abdullayev and Dilmurod Usmonov about the legal and economic implications of the initiative.
Constitutional concerns and practical challenges
Abdullayev said the Central Bank based its objections on Article 41 of the Constitution, which guarantees property rights as well as the confidentiality of bank transactions, deposits and accounts.
He noted that, while the Tax Committee relies on Article 11 of the Law on Bank Secrecy, which allows banks to provide information to tax authorities in matters related to taxation, the broader consequences of the proposal require careful consideration.
"Today, people increasingly lend and borrow money through bank card transfers instead of cash. Someone can ask a friend for money and receive it within minutes," Abdullayev said.
He acknowledged that some businesses in retail, catering and services accept payments on personal bank cards in violation of trading rules. However, he questioned whether such cases justify broader monitoring of all bank customers.
Abdullayev also pointed to practical difficulties in tax administration. Under the Tax Code, tax authorities may review unpaid tax liabilities for up to three years. Individuals could struggle to remember the purpose of transfers received years earlier or prove whether the money represented a loan, a gift or another non-taxable transaction, he said.
‘People may return to cash’
Usmonov said he has already encountered cases in which tax authorities questioned large sums credited to clients' personal bank cards.
In one case, he said, even transfers made solely to top up a bank card were initially treated as taxable income. Although supporting evidence was submitted and the tax authority agreed to review the matter, a final decision has yet to be issued.
"If this proposal is implemented, public trust in the banking system will decline," Usmonov said.
He added that many people may decide it is easier to conduct transactions in cash than risk being questioned by tax authorities over transfers received on their bank cards.
According to Usmonov, such a shift would ultimately strengthen the shadow economy rather than improve tax compliance.
