Georgia taxes residents on worldwide income and non-residents on Georgia-source income only. Georgia operates a self-assessment system, with the Revenue Service conducting post-filing review. Georgia's corporate tax follows an Estonian-style distribution model: retained and reinvested corporate profits face no Georgian corporate tax until actually distributed.
The Georgian tax year is the calendar year. Corporate tax is assessed monthly on actual distributions given Georgia's distribution-based system; the individual filing deadline is 31 March of the following year.
Georgia's headline corporate income tax (CIT) rate is 15% (20 for banks/microfinance).
The headline personal income tax (PIT) rate is 20%.
The standard VAT/GST (or equivalent consumption tax) rate is 18%.
An individual is tax resident if actually present in Georgia for 183 or more days in any continuous 12-calendar-month period ending in the relevant tax year (each day of presence counts regardless of hours present), or if serving abroad in Georgia's public service during that year. Time spent outside Georgia specifically for treatment, leisure, business travel, or education does not break the count of days actually present, and days already used to establish one 12-month residency period cannot be recounted toward a later period. Georgia also offers a High Net Worth Individual (HNWI) residency route requiring proof of Georgian assets of at least USD 500,000 or Georgian-connected income/asset thresholds, without the 183-day physical presence requirement. A company is tax resident if incorporated in Georgia or if its place of effective management (where the board of directors exercises decision-making) is in Georgia, though in practice Georgian tax authorities rely mainly on registration.
A non-Georgian entity has a Georgia permanent establishment through a fixed place of business or a dependent agent habitually concluding contracts in Georgia on the entity's behalf, following the OECD Model Treaty definition as applied under Georgian domestic law and any applicable tax treaty.
Retained corporate profits are not taxed at all (0%), with the 15% corporate rate applying only when profits are actually distributed as dividends - a system built around when income is realized rather than where a controlled entity sits, leaving no natural role for a CFC-style attribution rule. Note that Georgia's own absence of CFC rules does not affect a foreign tax resident's home-country CFC exposure over a Georgian company they control - that depends entirely on the shareholder's own country of tax residence, not on Georgian law.
No thin capitalisation rules are applicable in Georgia, independently corroborated by two further sources. Related-party transactions generally, including intra-group financing, remain subject to Georgia's transfer pricing rules, which apply the OECD's five recognized arm's-length methods (comparable uncontrolled price, resale price, cost plus, transactional net margin, and profit split).
Georgia does not use an elective check-the-box classification system; entity classification generally follows the entity's actual legal characteristics. Georgia is not an EU member and does not have a comprehensive ATAD2-style anti-hybrid regime.
No foreign bank account or foreign financial asset reporting regime exists requiring residents to separately disclose foreign accounts; foreign income is reported through the standard annual tax return.
Georgia has no Controlled Foreign Company regime. Given Georgia's distribution-based corporate tax system, dividends received by a Georgian company from a qualifying subsidiary are not taxed until further redistributed, functioning similarly to a participation exemption for reinvested profits.
Georgia has a real foreign tax credit regime for foreign tax paid on foreign-source income also taxed in Georgia upon distribution, capped at the Georgian tax otherwise due on that income.
Georgia maintains an extensive treaty network of over 55 double taxation treaties, including Germany, France, the UK, China, and most CIS countries; a separate source cites "over 50" as of late 2023, consistent with continued network growth. Georgia signed the OECD's Multilateral Instrument (MLI), which entered into force on 1 July 2019 and modifies the application of many of these treaties for BEPS-related purposes. A domestic dividend withholding rate of 5% applies by default, dropping to 0% where the recipient is a foreign company holding at least 10% (or, under some treaties, at least 50%) of the Georgian payer's capital or voting power - confirm the specific threshold under the applicable treaty before relying on a reduced rate.