If the tax authority suspends operations on bank accounts: in which four cases, what is not suspended and when is the decision cancelled?

"Sarvar Parket" LLC makes parquet. The accountant fell ill, and the monthly tax report was not filed by the deadline. Ten days have passed since the deadline expired. In the morning, outgoing operations stopped working in the bank's client cabinet, and in the taxpayer's personal account a notice appeared stating the reason. The director asks: "The account is blocked, what now?" This article answers that question under Articles 111–113 of the Tax Code (the company and figures were made up by the author and are hypothetical).

What is this decision and how does it differ from recovery?

Article 106 of the Code lists six ways to secure performance of an obligation: pledge, surety, bank guarantee, late-payment interest, suspension of account operations and seizure of property. So suspending an account is one of the security measures: it does not recover the tax debt, that is, it does not transfer money to the budget. It stops the company's outgoing operations and in this way pushes it to file the report or meet the demand.

Actually transferring the money is a different process: recovery of tax debt from funds on bank accounts (Chapter 15 of the Code). Do not mix the two: on a suspended account the money stays where it is, only outgoing payments cannot be made from it.

Who decides, for how long and how?

• The head of the tax authority (or his deputy) may suspend an account for no more than ten days. A longer suspension is possible only through a court: the tax authority files a petition, and until the court rules the operations remain suspended (Article 111, part one).
• The decision is sent to the bank in electronic form. At the same time a notice stating the reasons goes to the taxpayer's personal account (Article 111, part two). That is why the habit of opening the personal account once a day is useful.
• A note about days: Article 111 says "ten days", and the word "calendar" is not written. Under part seven of Article 5, a term counted in days, if it is not set in calendar days, is counted in working days. So when calculating the exact term, check it with the tax authority.

In which four cases may the accounts of a legal entity and an individual entrepreneur be suspended?

Part three of Article 111 gives four cases for legal entities and individual entrepreneurs. The list is complete; and part one of Article 112 sets the cancellation deadline for each case:

Two notes. First, under the fourth ground the taxpayer's representative must bring the necessary explanations in person to the tax authority where the taxpayer is registered (Article 112, part one, item 4). Second, absence may be recognized as justified, for example, if the taxpayer is registered with another tax authority but information about the new place of registration is unknown to the previous authority, and also in case of technical errors; the same may apply where a branch or separate subdivision has been liquidated or property has been sold (Article 112, parts two and three).

There is a separate rule for a consolidated group: if the responsible participant does not file the report within ten days after the deadline, the decision may be taken in respect of the operations of the responsible participant or of all participants of the group (Article 111, part five).

What exactly stops and what does the restriction not touch?

Under part four of Article 111, suspension means that banks suspend all outgoing operations on all accounts of the taxpayer. Not just one account: an account in another bank is also covered by this decision. The text speaks of outgoing operations; no restriction on incoming ones is written.

The cases where the restriction does not apply are in part six: (1) payments that under civil legislation are made first in priority; (2) accounts in banks on which recovery is not permitted under legislation. An important note: the Tax Code itself does not give the list of these payments, it refers to civil legislation. So do not assume "it will go through anyway" without checking, with the bank and the law itself, that a payment falls in that list.

What must the bank do and what restrictions fall on the company?

• The tax authority's decision must be executed by the bank unconditionally (Article 113, part one).
• The bank is not liable for losses suffered by the taxpayer as a result of the suspension of operations (part two).
• The suspension remains in force from the day the bank receives the decision until the day the cancellation decision is received (part three; except for the separate rule in part one of Article 111). So the real period of suspension depends on the day the cancellation decision reached the bank.
• After receiving the decision, the bank may not open a new account, deposit or term deposit, except accounts on which recovery is not permitted under legislation (part six). That is, the route "we will open a new account in another bank and keep working" is closed.

What changes in the books? The NAS No. 21 tables show no separate entry for suspension of accounts, and none is required: the money stays in the balance of 5110 where it is, only outgoing payments cannot be made from it. And the procedure for calculating contractual penalties for late payments is set in the accounting policy and the contract.

Example: how much does a six-day suspension cost the company?

"Sarvar Parket" did not file its report on time, and a decision was issued under item 1 of part three of Article 111. The accountant filed the report, the decision was cancelled and the bank received the cancellation decision; altogether the suspension lasted 6 calendar days (hypothetical). Three payments fell on those days. The penalty percentages below are taken from the contract, that is, from a hypothetical term made up by the author (0.1% a day), and have nothing to do with the Code:

Calculation: 90 000 000 × 0.1% × 6 = 540 000; 35 000 000 × 0.1% × 6 = 210 000; 540 000 + 210 000 = 750 000; 90 000 000 + 35 000 000 + 12 000 000 = 137 000 000. The cash balance stood the same from start to finish: at the start there were 240 000 000 soums on the accounts, during the suspension 185 000 000 soums came in from customers (in Article 111 the restriction is written only for outgoing operations), 425 000 000 soums in total; after the unpaid 137 000 000 soums goes out, the balance would be 425 000 000 − 137 000 000 = 288 000 000 soums. That is, the problem is not a lack of money, it is a 6-day delay and a penalty of 750 000 soums because of one unfiled report.

What if the tax authority cancels late or the decision is unlawful?

Article 112 also protects the company: - If the deadline is breached. If the tax authority misses the deadline for cancelling or for sending the decision to the bank, interest runs on the suspended sum of money and is paid to the taxpayer by the tax authority for each calendar day of delay (part six). The deadline for sending the decision to the bank: no later than the day after the day the cancellation decision is made (part four). - If the decision is unlawful. If an unlawful decision has been issued, interest is charged on the amount of funds subject to the suspension regime for each calendar day from the day the bank received the decision until it receives the cancellation decision (part seven). - Interest rate. In these cases the rate is set equal to the refinancing rate of the Central Bank of the Republic of Uzbekistan (part eight).

The Code does not say in detail how to calculate (simple or compound interest), and the rate figure is not in the text of the article, so the interest amount was not calculated in the table. If there is a claim, the amount will have to be determined by agreement with the tax authority or through a court.

Is late-payment interest charged?

Under part five of Article 110, on a debt that the taxpayer could not pay because the tax authority issued a decision to suspend account operations or to freeze funds, late-payment interest does not run, and it is not charged for the whole period this circumstance continued. As the text shows, the rule applies only to tax debt unpaid for that reason. The general rule on late-payment interest is as follows: unless the Code provides otherwise, it is charged for each calendar day of delay starting from the day after the day the tax must be paid (Article 110, part three); the other parts of Article 110 also contain separate exceptions. In your specific case, check with the tax authority which part exempts from late-payment interest.

Practical advice

• Keep control of the reporting calendar. The first ground is precisely the report: if it is not filed within ten days after the deadline, a decision may be issued. Appoint a second accountant or set a reminder.
• Check the personal account every day. The notice arrives there with the reasons (Article 111, part two), and depending on the reason it becomes clear what must be filed.
• To speed up cancellation, document the day you filed. Under the report ground the cancellation deadline runs from the day the report is filed (Article 112, part one, item 1): keep the confirmation of electronic filing (the receipt).
• Watch the deadline for answering a desk-audit demand. This is the second ground: if explanations and corrections are not filed by the set deadline, the account may be suspended.
• Keep your address and place of registration up to date. The fourth ground is absence from the address: if you have moved the office, update your registration data in advance, and your representative must submit the explanation in person.
• Think in advance about the consequences of delay in contracts with customers and suppliers. The 750 000 soums penalty in the example came not from tax but from the contract terms.
• Check the current version of the Code. This article relies on the text of the Tax Code as of 6 August 2026; next to some parts of Articles 111 and 112 there is a mark "See the next version", that is, a later change is possible. On the day the decision is issued, re-check the current text.
• Find out in advance from the bank and from civil legislation the list of first-priority payments. Which payments do not fall under suspension, the Tax Code itself does not list.