What we asked
After studying the Procedure implementing the pilot project, approved by Order №1/06 of the Agency for Innovation and Digital Technologies under the President of the Republic of Tajikistan, we identified a number of questions the document does not answer directly. On 28 July 2026 we submitted nineteen questions to the Agency for Innovation and to the Tax Committee. On 17 August the Agency responded — letter №01-16/2048.
The start date is confirmed
The Agency confirmed that the pilot project runs from 1 September 2026 for two years. Until now this date appeared only in media reports — the Procedure itself does not state it, referring instead to entry into force after state registration and official publication, and to a three-month preparatory period.
Wallets are counted together
The most practically significant answer concerns thresholds. We asked whether transactions are counted separately for each wallet when a person holds wallets at several banks. The answer: the number of incoming payments is counted on an aggregate basis across all electronic wallets registered to one individual across different credit and financial institutions. Separate counting for each individual wallet is not provided for by the mechanism.
This matters for anyone using more than one wallet. The thresholds — more than 10 commercial payments per day and more than 80 transfers per month — apply to the person, not to the individual wallet. Opening a second wallet at another bank does not move you outside the thresholds.
What else was clarified
The National Bank of Tajikistan is designated as the system operator, and the joint-stock company "Certification Centres, State Services and Digital Software Development" under the Agency as the technical operator. The commercial nature of a transaction is confirmed by the sender through a mobile application, and the system is required to accept and reflect that confirmation. Cashback is not included in the tax base. Use of a cash register or a virtual cash register is mandatory for participants.
The threshold mechanism was also confirmed: more than 10 commercial payments in a day in favour of one person results in a referral to the tax authority regarding registration as an individual entrepreneur, after which all subsequent funds arriving in that wallet are taxed. More than 80 non-commercial transfers in a month results in a referral for assessment of whether entrepreneurial activity is being conducted.
Questions still unanswered
The Agency referred part of our questions to the competence of the Tax Committee: the legal grounds for refunding overpaid or erroneously paid amounts, the application of tax rates and exemptions, the determination of taxpayer obligations, and the establishment of the fact of entrepreneurial activity. The Agency noted that official clarifications on these matters are issued by the authorised body within its competence.
On the status of these clarifications
We submitted these questions in our own name, and the Agency replied to us. The answers address the questions we asked and explain the general rules of the regime. If your question falls outside them, request a clarification from the tax authority for your own situation: formal protection follows only from a response issued on your own application.
What to do now
Less than two weeks remain before the pilot begins. Our calculator has been updated to reflect this clarification — it is anonymous, requires no name or taxpayer number, and runs the calculation on your own device. There are two versions: a quick one, which takes two figures and returns an answer, in Tajik and Russian — tajiklaw.ai/calc; and a detailed one, with a checklist of excluded activities, references to specific clauses of the Procedure and a breakdown of the methodology, for cases where the calculation must be presented to a client or to management — tajiklaw.ai/3percent.
This is legal information, not legal advice. For your specific situation, consult a specialist.