Tax Code of Georgia

LAW OF GEORGIA

TAX CODE OF GEORGIA

SECTION I

GENERAL PROVISIONS

Chapter I – Georgian Tax System

Article 1 – Scope of regulation of the Tax Code of Georgia

This Code defines, in accordance with the Constitution of Georgia, the general principles of formation and operation of

the tax system of Georgia, the legal status of tax payers and competent authorities, the types of tax offences, the liability

for violating the tax legislation of Georgia, the procedure and conditions for appealing wrongful acts of competent

authorities and their officials, the procedure for settling tax disputes, and governs the legal relations connected with the

fulfilment of tax liabilities.

Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012

Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019

Article 2 – Tax legislation of Georgia

1. The tax legislation of Georgia comprises the Constitution of Georgia, international treaties and agreements, this Code

and subordinate normative acts adopted in compliance with them.

2. The tax legislation of Georgia in effect at the moment when tax liability arises shall be used for taxation.

3. The Government of Georgia or the Minister of Finance of Georgia shall adopt/issue subordinate normative acts for

enforcing this Code.

4. (Deleted – 26.12.2013, No 1886).

5. To enforce the tax legislation of Georgia, the head of the Legal Entity under Public Law (LEPL) within the Ministry of

Finance of Georgia – the Revenue Service (‘the Revenue Service’) shall issue orders, internal instructions and guidelines

on application of the tax legislation of Georgia by tax authorities.

6. When regulating tax matters, the terms and concepts of the legislation of Georgia used in this Code shall have the same

meanings as they have in the respective legislation, unless otherwise provided for by this Code.

7. Any international tax-related treaty that has been ratified by the Parliament of Georgia and that has entered into force

shall prevail over this Code.

Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013

Article 3 – Setting timeframes

1. The timeframes set by this Code shall be determined by a specific calendar date or a period calculated in years, months

or days and/or by reference to the appropriate circumstance.

2. The timeframe set by this Code shall commence on the day following the performance of the relevant action. A day

may be a business day or a calendar day. If not specified, a day shall be a calendar day. Unless otherwise provided for by

the tax legislation of Georgia, a business day shall coincide with a calendar day, except for a Saturday, Sunday and the

holidays determined by the Organic Law of Georgia on the Labour Code of Georgia.

3. The timeframe calculated in years shall end in the respective month and day of the last year of the timeframe.

4. The time frame calculated in months shall end on the respective day of the last month of the timeframe.

5. An action for which a timeframe is set may be performed by the end of the last business day of the timeframe, and if

the action is performed through a bank transfer, mail and/or electronic means, the action may be performed by 24:00 of

the last day of the timeframe.

6. If the last day of the performance of the action coincides with a non-business day, the timeframe for the action shall be

extended to the end of the next business day, and where the action is performed through a bank transfer, mail and/or

electronic means, the action may be performed by 24:00 of the next business day.

7. A calendar year shall be the period from 1 January through 31 December of any year; for a newly registered taxpayer a

calendar year shall be the period from the registration date through 31 December of the same year, unless otherwise

provided for by this Code.

8. A year (other than a calendar year) is a period consisting of any consecutive 12 calendar months.

Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013

Article 4 – Period of limitation

1. The period of limitation for assessing taxes to a taxpayer and for submitting a notice of tax liability to the taxpayer shall

be three years, unless otherwise provided for by this Code.

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2. The period referred to in the first paragraph of this article shall commence from the end of the calendar year in which

the respective tax liability arose.

3. The period of limitation for imposing sanctions (other than a penalty) under this Code on a taxpayer and for submitting

a relevant tax notice to a taxpayer shall be three years, unless otherwise provided for by this Code.

4. The period referred to in the third paragraph of this article shall commence:

a) from the end of the calendar year in which the tax offence was committed, except as provided for by subparagraph (b)

of this paragraph;

b) from the end of the calendar year in which the tax liability arose, if the calculation of the amount of the sanction

provided for in this Code is related to the amount of the tax liability.

5. The period of limitation for a tax audit of taxpayers shall be three years, unless otherwise provided for by this Code.

6. The period referred to in the fifth paragraph of this article shall commence from the end of the calendar year in which

the audit takes place.

7. The period of limitation referred to in the first, third and fifth paragraphs of this article shall be extended for one year if

less than a year remains before the expiry of the period and the taxpayer has filed with a tax authority a taxpayer’s claim

or a tax return (including an adjusted tax return) for the relevant period.

8. The period of limitation for a taxpayer to file a taxpayer claim with a tax authority shall be three years, which will be

calculated from the end of a calendar year in which the right to refund for the sum of any overpaid tax and/or sanction

(including customs sanction) arose.

9. The period of limitation for serving an individual administrative-legal act on tax enforcement measures as provided for

in this Code to a taxpayer, registration authority or banking institution shall be three years, commencing from the end of

the calendar year in which the tax arrears were incurred.

10. In the cases provided for in the ninth paragraph of this article, the period of limitation for serving an individual

administrative-legal act shall be suspended:

a) from the entry into force of a ruling on recognising as admissible a person’s application for insolvency and on opening

the rehabilitation or bankruptcy regime till the end of the regime concerned, and during the validity period of the

rehabilitation plan;

b) (Deleted – 6.3.2024, No 4056);

c) during a tax dispute;

d) during the validity period of an agreement for deferral of enforced payment of tax arrears;

e) during the validity period of a tax agreement act;

f) where so provided for by Article 238(7)(a) of this Code.

11. The periods of limitation provided for by this article shall not apply:

a) during the enforcement period of a judgment of a court/dispute resolution body by a tax authority;

b) in relation to the submission of a motion for recognising a person as a straw man for a taxpayer by a tax authority to the

court on the basis of Article 246 of this Code, and to the application of measures of securing the enforcement of payment

of tax arrears, as provided for by this Code, against the straw man for the taxpayer.

12. When the loss is carried forward for 3 years or more, the period of limitation under paragraphs 1, 3 and 5 of this

article in relation to the tax liabilities of a calendar year the loss was incurred, the amount of which is affected by such

loss shall be extended and it shall exceed the loss carry forward period by one year. In such a case, the period of limitation

shall be counted from the end of the calendar year the loss was incurred.

13. The period of limitation under paragraphs 3 and 5 of this article for submitting a tax notice to a tax payer shall not be

considered laches if a tax authority has posted the tax notice on the tax payer’s authorised user web page before expiry of

the period of limitation.

Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012

Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012

Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012

Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013

Law of Georgia No 3581 of 1 May 2013 – website, 15.5.2015

Law of Georgia No 3583 of 1 May 2013 – website, 15.5.2015

Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015

Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017

Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019

Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020

Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023

Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023

Law of Georgia No 4056 of 6 March 2024 – website, 14.3.2024

Article 5 – Principles of the tax legislation of Georgia

1. A person shall pay national and local taxes established under this Code.

2. No tax obligation introduced in violation of this Code or not provided for in this Code may be imposed on a person. No

http://www.matsne.gov.ge 20000000005001016012

person may be forced to pay taxes earlier than required by this Code.

3. A municipality representative body may introduce only the local tax provided for by this Code.

Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020

Article 6 – Concept and types of taxes

1. A tax is a mandatory, unconditional monetary payment to the budget made by a taxpayer in accordance with this Code,

based on the necessary, non-equivalent and gratuitous character of the payment.

2. Taxes shall be national and local.

3. National taxes shall be the taxes provided for under this Code, the payment of which is mandatory across the whole

territory of Georgia.

4. A local tax shall be a tax imposed by this Code and introduced by a normative act of the municipality representative

body – Sakrebulo (within marginal rates), the payment of which is mandatory within the administrative boundaries of the

municipality concerned.

5. National taxes shall be:

a) income tax;

b) profit tax;

c) value added tax (VAT);

d) excise tax;

e) import duty;

6. A property tax shall be a local tax.

Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020

Article 7 – imposing and introducing a local tax; changing its payment conditions and abolishing the tax

1. A municipality representative body may introduce a local tax imposed by this Code as a flat rate tax within the

administrative boundaries of the municipality and/or according to individual branches and/or types of businesses within

the administrative boundaries of the municipality, within the marginal rates set by this Code.

2. A municipality shall forward information on introducing a local tax, changing its payment conditions or on abolishing

the introduced local tax and a copy of the relevant normative act upon publication to the Revenue Service of Georgia and

to the appropriate tax authorities.

Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012

Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020

Article 7 1 – Requirements for payment accounts opened with payment service providers

1. Provisions defined by Articles 54, 71, 238(1)(c) and (e), 241(7), (8), (10) and (11), and Article 243(1), (2) and (4) of this

Code for a banking institution with respect to a bank account shall apply to a payment account of a tax payer opened with

a payment service provider registered in accordance with the Law of Georgia on Payment Systems and Payment Service if

he/she has included a legal person, or an individual entrepreneur registered in accordance with the legislation of Georgia,

and another organisational entity in the electronic money scheme, as a payer.

2. If a payment service provider provided for by paragraph 1 of this article fails to fulfil the respective obligation,

liabilities defined by Article 283 of this Code shall apply to it respectively.

3. For the purposes of paragraph 1 of this article, the tax authority shall refer to the list of payment service providers

published on the webpage of the National Bank of Georgia under Article 18(11 2 ) of the Law of Georgia on Payment

Systems and Payment Service.

Law of Georgia No 1808 of 9 September 2022 – website, 23.9.2022

Chapter II – Terms and Concepts Used in This Code

Article 8 – Definition of terms

1. Non-depreciable fixed asset – a fixed asset not losing its value during the process of operation.

2. Intangible asset – an identifiable non-monetary asset without physical substance used by a person for manufacturing

goods, supplying goods/rendering services, leasing it to others and/or for administrative purposes. Intangible assets

include: copyright, patent, trademark, goodwill, software, licence, leasehold, franchise, mining rights, special import and

export rights and other similar intangible assets.

3. Indirect tax – a tax (value added tax, excise tax, import duty) imposed as an addition to the price of goods supplied

(imported) and/or services rendered and that is paid by a consumer (importer) when purchasing (importing) goods and/or

services at the price increased by such tax. The obligation to pay an indirect tax to the budget is imposed upon the

supplier (importer) of goods and/or services who is referred to as a taxpayer for the purposes of this Code.

4. Non-resident – a person who is not a resident.

5. Acknowledged tax arrears – tax arrears if:

a) the basis of tax assessment is a tax return/customs declaration;

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b) a person has failed to appeal a tax notice issued by a tax authority, or the decision of a dispute resolution authority,

within the timeframe set by this Code;

c) the Revenue Service and a taxpayer have signed an agreement to reduce tax arrears;

d) a court decision on the lawfulness of the tax assessment has taken effect;

e) a person, by a written/electronic application, has refused to appeal against the decision of a tax dispute resolution body;

f) a person has submitted a written application to a tax authority under the procedure determined by the Minister of

Finance of Georgia for refusing to appeal the tax notice.

6. Biological asset – an animal or a plant.

6 1 . Agricultural activity – activity under International Accounting Standards 41.

6 2 . Agricultural produce – produce obtained from agricultural activity. At the same time, changing of a commodity

classification code as a result of biological transformation or harvesting product from a biological asset (detachment of

produce or the cessation of the life process of a biological asset) shall not be considered as industrial processing (changing

commodity classification code) of agricultural produce.

6 3 . Agricultural cooperative – a legal person that has been granted the status of an agricultural cooperative under the Law

of Georgia on Agricultural Cooperatives.

7. International Accounting Standards (‘IAS’) – the standards approved by the International Accounting Standards

Committee and introduced for application under the resolution of the Commission of Accounting Standards of the

Parliament of Georgia.

8. Administration of taxes – a set of forms, methods and rules employed by tax authorities when enforcing the tax

legislation of Georgia to ensure the computation, payment and declaration of taxes, as well as tax control, registration and

notification of taxpayers, and the fulfilment of tax liabilities.

9. Taxpayer identification number – a number allocated to a taxpayer under the tax legislation of Georgia.

10. Long-term contract – a contract that is not completed in the same calendar year in which the services under the

contract commence and when it contracts for the manufacture, installation, construction or delivery of services related to

those activities, except for a contract that expires within six months after the commencement of the services under the

contract.

11. Shortage – shortage of inventory and/or fixed assets identified during the comparison (including by means of stock-

taking) of inventory and/or fixed assets with a taxpayer's accounting records. Shortage in connection with inventory that

cannot be physically warehoused (electric and thermal energy, gas and water) shall be the difference between the

purchased (according to proof of purchase documents) and the sold (actually released from a taxpayer) inventory,

provided that the customer (payer) and/or the person misappropriating the inventory and/or fixed assets cannot be

identified. At the same time, a competent authority may set a maximum amount of loss. In such case, the loss in excess of

that amount shall be deemed as shortage. In the case of stamping/marking of the goods in immaterial form in accordance

with procedures determined by the tax legislation of Georgia, the loss identified by the manufacturer in the process of

manufacturing shall not be deemed as shortage.

12. Dividend – any income (including interest from preference shares) earned by a shareholder/interest-holder from

shares or rights (interests) as a result of a distribution of profits made by a legal person to its shareholders/interest-holders

in proportion, or not in proportion, to their shares/rights in the capital. Where a repo agreement, securities lending and

financial collateral are involved, a compensatory amount received by a seller/lender from a buyer/lendee, which is the

dividend actually received from the securities during the validity period of such transaction. In addition, dividends shall

not include:

a) payments/disbursements made in cash or in kind at the time of liquidation of a legal person or at the time of buying out

shares/interest, which does not exceed the amount of the contribution made by a shareholder/partner to the capital

(outstanding and additional paid-in capital);

b) payment made to a shareholder/interest-holder of a legal person by transferring the shares/interest of the same legal

person into ownership, except for transferring by a resident legal person the equity securities issued through a public

offering in Georgia and allowed for trading on an organised market recognised by the National Bank of Georgia.

13. (Deleted – 23.12.2017, No 1935).

14. Compensation – property and/or benefit received by a person in compensation for the supply of goods, rendering of

services, costs, loss or shortage.

15. Tangible asset – any asset that is not an intangible asset.

16. Family – a person, his/her spouse, minor children and step-children, as well as parents, children and step-children,

sisters, brothers, grandmothers, grandfathers, grandchildren permanently living with the person while maintaining a

common household. For the purposes of this Code, a taxpayer shall unconditionally define the circle of persons (from the

above ones) who live with him/her permanently and maintain a common household.

17. Partner – a partner, a shareholder, a limited partner, a general partner, a member of a cooperative under the Law of

Georgia on Entrepreneurs.

18. Person – a natural or legal person under the Civil Code of Georgia, an enterprise, or an organisation under the Tax

Code of Georgia.

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19. Interest – any pre-declared (established) income (including that received as a discount) from any debt claim related to

cash investments or debt obligations (whether backed by mortgage or securitised in any other way). At the same time, for

the purposes of this paragraph:

a) debt obligations shall not include debt obligations arising from the supply of goods and/or rendering of services, or

obligations arising from guarantee and/or surety and/or other similar transactions;

b) the following shall be regarded as interest:

b.a) (Deleted – 28.6.2023, No 3350);

b.b) an amount payable in respect of a credit (loan), deposit, bond;

b.c) income from government securities and bonds, including the premiums and profits accrued on them;

b.d) part of the sum of a difference between the securities supply price and purchase price, in the amount of an unpaid

interest accrued on the securities before the moment of their supply;

b.e) within a repo agreement, a difference between the loan securities selling price and a pre-agreed redemption price of

this or other equivalent loan securities;

b.c) within a repo agreement, securities lending or financial collateral, a sum of payment received by a seller/lender from

a buyer/lendee, which is an interest accrued on the securities within the validity period of this transaction and actually

received by the buyer;

c) a penalty for delayed payment or delayed delivery shall not be regarded as interest.

20. Resident – a resident natural or legal person (a Georgian enterprise or a Georgian organisation).

21. Royalty:

a) a fee for the right to use subsoil in the course of extracting minerals and processing anthropogenic formations;

b) income received for the right to use copyrights, software, patents, drawings, models, trademarks or other intellectual

property or for transferring the right to another person;

c) income received for the right to use industrial, trade or research equipment or for transferring the right to another

person;

d) income received for the use of know-how;

e) income received for the right to use cinematograph films, video films, audio records or other recording devices or for

transferring the right to another person;

f) income received for the right to use a secret formula or process, as well as information containing industrial,

commercial or scientific experience or for transferring the right to another person;

g) income received for providing technical assistance in connection with the rights provided for in this paragraph or from

the waiver of these rights.

22. Accounting documents – source documents (including tax source documents), ledgers and other documents on the

basis of which objects of taxation and objects related to taxation are determined and tax liabilities are established.

23. Tax arrears – the difference between the amount of taxes and/or sanctions (including a customs sanction) not paid

within the set time limit by a taxpayer and the overpaid amount of taxes and/or sanctions (including a customs sanction).

24. Foreign Economic Activity Commodity Nomenclature – a system of commodity classification codes, adopted under

the International Convention on Harmonization of Commodity Description and Coding System.

25. International carriage – any carriage of passengers or goods (including mail) by a motor vehicle, railway vehicle,

marine vessel, internal land water vehicle or an aircraft between two points located in different states, one of which is

Georgia. In addition, an international carriage shall not include:

a) carriage performed only between points located outside the borders of Georgia or only between points within the

borders of Georgia;

b) transportation of goods through pipelines or power transmission lines.

26. additional paid-in capital – the difference between the amount received or receivable by an enterprise from an initial

public offering of shares and the total nominal value of those shares, as well as the excess of the value of non-cash

contributions made at the moment of founding of an entrepreneurial company over the agreed upon amount.

27. Profit received from a person engaged in gambling business – income that is a positive difference between the amount

received by a natural person (player) from one ticket, counter, coin and/or other means of gambling and games of chance

and the amount of the stake and/or the cost of the item.

28. Inventory – raw materials, materials, semi-finished goods, spare parts, containers and finished products (goods) used

by a person in the ordinary course of business under International Accounting Standards.

29. Bad debt – claim or part of it recognised by a taxpayer as a result of the sale of goods and/or services or as a result of

the prepayment made in respect of such sale, the due date of which has expired and which has not been paid by the end

of the current tax year, and at the same time one of the following documents are available:

a) a legally effective court/arbitration decision on refusal to satisfy the claim;

b) a notice issued by an enforcement agency regarding the non-receipt or partial receipt by a creditor of the amount

payable to him/her as a result of the enforcement of a writ of execution;

c) a legally effective court ruling on recognising as admissible an application for insolvency and on opening the

rehabilitation or bankruptcy regime in relation to a person in question, unless the judge has recognised the creditor’s

claim;

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d) a notice of revocation of registration issued by the Register of Entrepreneurial and Non-entrepreneurial (Non-

commercial) Legal Entities or a death certificate.

30. Property – assets of every kind both tangible and intangible, which can be purchased, possessed, managed and used by

persons without limitation.

31. Fixed asset – a tangible asset that a person uses for manufacturing goods, supplying goods/rendering services, for

renting out (including leasing out) and/or for administrative purposes, the useful life of which is longer than a year.

32. Fixed asset repair costs – costs, which increase the initial (original, standard) efficiency of fixed assets (including,

modification (reconstruction) of the elements of buildings and structures to prolong their useful life and increase their

efficiency; improvement of the parts of equipment and machinery to increase their efficiency, and introduction of new

production processes), other than current maintenance costs, which are incurred in relation to restoring and maintaining

the initial efficiency of the fixed assets.

33. Entertainment expenses – expenses incurred by a person within the scope of economic activity, which include:

a) expenses (for juices, mineral waters, soft drinks, tea, coffee, breakfast, lunch, dinner, banquet) related to events

(presentations, receptions) arranged on behalf of a person;

b) expenses for excursions and cultural and entertainment events;

c) souvenir costs;

d) guest service costs, including:

d.a) consular service (visa processing and extension) costs;

d.b) costs of meeting and departure at an airport (VIP Hall service);

d.c) transportation costs;

d.d) hotel service (reservation, accommodation) costs;

d.e) costs related to receptions and parties (juices, mineral waters, soft drinks, tea, coffee, breakfast, lunch, dinner, and

banquets).

34. Net assets – difference between a person's assets and liabilities.

35. A virtual zone person – a legal person engaged in IT activities and holding an appropriate status.

36. Information Technologies (IT) – studying, supporting, developing, designing, producing and introducing computer

information systems, as a result of which software products are obtained.

37. Tourist zone entrepreneur – a person (entrepreneurial entity) who builds a hotel and ensures its operation under the

Law of Georgia on Promoting the Development of Free Tourist Zones.

37 1 . Agro tourism operator – a person granted the status of agro tourism operator in accordance with an ordinance of the

Government of Georgia.

37 2 . Wine tourism operator – a person granted the status of wine tourism operator in accordance with an ordinance of the

Government of Georgia.

38. Leasing – leasing within the meaning of the Civil Code of Georgia, if the leased item is a depreciable asset.

39. Leasing Company – an enterprise whose income from leased out property during a calendar year is at least 70% of its

income.

40. Donation – goods/services, including funds received by an organisation as gifts.

41. High-mountain settlement – a high-altitude settlement as defined by the Law of Georgia on the Development of

High-mountain Areas.

42. High-mountain settlement enterprise – an enterprise/individual entrepreneur that carries on business in a high-

mountain settlement and enjoys the status of a high-mountain settlement enterprise under the Law of Georgia on the

Development of High-mountain Areas.

43. Net profit – any profit that can be distributed as dividend, under the procedure established by the legislation of

Georgia.

44. Income – any income according to the international accounting standards.

45. Loan provider – an entity providing loans under the Organic Law of Georgia on the National Bank of Georgia.

46. Taxation year – a calendar year.

47. Import – placement of goods under the Release for free circulation procedure in accordance with the Customs Code of

Georgia.

48. Temporary admission – placement of goods under the temporary admission procedure in accordance with the

Customs Code of Georgia.

49. Customs sanction – a measure of liability for a customs offence provided for by the Customs Code of Georgia.

50. Export – placement of goods under the export procedure in accordance with the Customs Code of Georgia;

51. Repo agreement, reverse repo agreement – a transaction defined by the Law of Georgia on Financial Collateral,

Mutual Deduction and Derivatives, if the transaction has been concluded in compliance with market principles, securities

are redeemed during 12 months from their sale and this transaction provides for payment by the buyer to the lender of an

interest accrued on the securities and actually received during the validity period of the agreement, a dividend (voucher)

or any other distribution, which means the equivalent payment thereof.

52. Securities lending – a transaction defined by the Law of Georgia on Financial Collateral, Mutual Deduction and

Derivatives, if the transaction has been concluded in compliance with market principles, securities are returned during 12

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months from their primary supply and this transaction provides for payment by the lendee to the lender of an interest

accrued on the securities and actually received during the validity period of the agreement, a dividend (voucher) or any

other distribution, which means the equivalent payment thereof.

53. Financial collateral – a transaction defined by the Law of Georgia on Financial Collateral, Mutual Deduction and

Derivatives.

54. Derivative – a transaction defined by the Law of Georgia on Financial Collateral, Mutual Deduction and Derivatives.

55. Banking institution – a commercial bank defined by the Law of Georgia on Commercial Bank Activities, or a

microbank provided or by the Law of Georgia on Microbank Activities.

56. Entity in the process of winding up (wound up company) – an entity (except for a branch established by a natural

person, who is an entrepreneur natural person) against which the commencement of the process of winding up has been

registered, under the Law of Georgia on Entrepreneurs (the liquidation process of which has been in progress).

Law of Georgia No 4061 of 15 December 2010 – LHG III, No 75, 27.12.2010, Art. 469

Law of Georgia No 4705 of 20 May 2011 – website, 1.6.2011

Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011

Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011

Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011

Law of Georgia No 5452 of 9 December 2011 – website, 22.12.2011

Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011

Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012

Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012

Law of Georgia No 817 of 12 July 2013 – website, 5.8.2013

Law of Georgia No 906 of 30 July 2013 – website, 20.8.2013

Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013

Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015

Law of Georgia No 4037 of 16 July 2015 – website, 28.7.2015

Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015

Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016

Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017

Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017

Law of Georgia No 4225 of 27 December 2018 – website, 31.12.2018

Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019

Law of Georgia No 5677 of 20 December 2019 – website, 31.12.2019

Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020

Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020

Law of Georgia No 884 of 2 August 2021 – website, 4.8.2021

Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023

Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023

Law of Georgia No 3317 of 28 June 2023 – website, 18.7.2023

Law of Georgia No 3350 of 28 June 2023 – website, 19.7.2023

Law of Georgia No 3922 of 13 December 2023 – website, 27.12.2023

Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023

Article 9 – Economic activity

1. Any activity shall be considered economic activity if it is performed to gain income or compensation, irrespective of the

result of the activity, unless otherwise provided for by this Code.

2. The following shall not be economic activity:

a) activity of public authorities, national regulatory and municipality bodies, which is directly related to the performance

of the functions assigned to them under the legislation of Georgia, other than the delivery of paid services under a

contract;

b) charitable activity;

c) religious activity;

d) hired work;

e) placement of funds by natural persons into deposit accounts in banking institutions and other credit institutions;

f) types of activities and/or operations and/or a set of operations defined by order of the Minister of Finance of Georgia, in

agreement with the Financial-Budget Committee of the Parliament of Georgia.

3. Free delivery of goods/services shall be deemed as economic activity if performed by:

a) an enterprise;

b) an entrepreneur natural person within the framework of the activity provided for by Article 2(2) and Article 3(1 and 2)

of the Law of Georgia on Entrepreneurs.

Law of Georgia No 1588 of 20 November 2013 – website, 3.12.2013

http://www.matsne.gov.ge 20000000005001016012

Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013

Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020

Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020

Law of Georgia No 884 of 2 August 2021 – website, 4.8.2021

Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023

Article 10 – Charitable activity

1. Charitable activity shall include:

a) voluntary and gratuitous assistance rendered directly or through a third person, to persons who need such assistance,

including:

a.a) to natural persons in need of social protection, natural persons in need of medical assistance, to low-income natural

persons (including, persons with disabilities, the elderly, orphan children, those that have lost breadwinners, persons with

international protection and internally displaced persons from the occupied territories – ill persons, multi-child families

and their members, people affected by wars, armed conflicts, accidents, natural disasters, catastrophes, epidemics and/or

epizooties.

a.b) to organisations providing services to children, the elderly and persons with disabilities, including fostering

institutions, residential schools, boarding schools, early and preschool fostering and educational institutions and other

children facilities, soup kitchens for serving the elderly, medical institutions, and rehabilitation centres;

a.c) to charitable organisations;

a.d) to religious organisations;

a.e) to specially gifted natural persons – to develop their talent;

a.f) to penitentiary institutions – to improve care and medical services of persons placed in these institutions;

a.g) to persons engaged in the activity provided for in paragraph 1(b) of this article;

b) the performance of socially beneficial activities by organisations in the following spheres: protection of human rights,

protection of environment, development of democracy and civil society; culture, education, science, healthcare, social

protection, physical education, amateur sports, and art.

2. Charity shall not include activities referred to in the first paragraph of this article if the activities are:

a) performed by the state and municipality bodies;

b) performed to support an enterprise, a political party or any other person participating in elections;

c) performed by a natural person for his/her own relatives or by a legal person for the heads of its management bodies and

their relatives;

d) regarded as sponsorship by the Law of Georgia on Advertising.

Law of Georgia No 5371 of 6 December 2011 – website, 20.12.2011

Law of Georgia No 3530 of 1 May 2015 – website, 18.5.2015

Law of Georgia No 5372 of 8 June 2016 – website, 24.6.2016

Law of Georgia No 57 of 1 December 2016 – website, 15.12.2016

Law of Georgia No 499 of 23 March 2017 – website, 27.3.2017

Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020

Law of Georgia No 845 of 26 June 2025 – website, 3.7.2025

Article 11 – Religious activity

1. Religious activity shall be the activity of duly registered religious organisations (associations) aimed at disseminating

religion and belief, including by means of:

a) organising and holding religious rites, ceremonies, prayers and other religious acts;

b) giving opportunity to believers to have or use buildings of worship or ceremonial structures to satisfy religious needs,

both jointly and individually;

c) organising reception and departure of religious delegations, pilgrims, representatives of different confessions, organising

national and international religious conferences, congresses and seminars, providing hotel (or other) accommodation,

transport, food and cultural services to the participants during such events;

d) maintaining monasteries, minsters, theological educational institutions, teaching students and listeners of those

theological educational institutions, maintaining charitable organisations (hospitals, shelters, specialised facilities for the

elderly and persons with disabilities), and other similar statutory activities under canonical rules.

2. The activity of the enterprises of those religious organisations (associations) that publish religious (religious service)

literature or produce objects of religious significance shall be treated as religious activity; the activity of these

organisations (associations) or of their enterprises that is related to the sale (dissemination) of religious (religious service)

literature or objects of religious significance; as well as the use of funds derived from such activity to perform religious

activity.

Law of Georgia No 845 of 26 June 2025 – website, 3.7.2025

Article 12 – Hired work

http://www.matsne.gov.ge 20000000005001016012

1. Hired work shall mean:

a) performance of obligations by a natural person within the scope of the relations governed by the labour legislation of

Georgia and/or of a foreign country;

b) performance of an obligation by a natural person, which is related to his/her service in the defence forces, law

enforcement bodies of Georgia and other equivalent bodies;

c) holding the position the head (director) of an enterprise (organisation) by a natural person or carrying out the duties of

the head (director) of an enterprise or an organisation;

2. For the purposes of this Code, a hired natural person shall be referred to as an employee, a person paying compensation

for the work performed by such natural person shall be referred to as an employer and such compensation shall be

referred to as a salary.

3. The employer shall enter information about the hired persons provided for in this article into the register of hired

persons, which is maintained by the Revenue Service.

4. The list of information to be entered into the register of hired persons and the procedure for entering information shall

be defined by an order of the Minister of Finance of Georgia.

Law of Georgia No 3600 of 31 October 2018 – website, 21.11.2018

Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020

Article 13 – Goods

1. Goods shall be a tangible or an intangible property, including electric and thermal energy, gas and water.

2. (Deleted – 14.7.2020, No 6817).

Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020

Article 14 – Service

1. Activity that is not a supply of goods shall be regarded as service. Unless otherwise provided for by the tax legislation of

Georgia, service shall include:

a) construction and installation;

b) repair;

c) restoration;

d) development;

e) geological and exploratory activities;

f) transportation, including transportation of gas, oil, oil products, electric and thermal energy;

g) property letting, renting or leasing;

h) intermediary’s activities;

i) personnel selection;

j) transfer of the right to use patents, certificates, licenses, trademarks, service marks, intellectual property and other

personal non-property rights;

k) fulfilment of obligations – acting or refraining from action;

l) communication service, household and public utility services;

m) advertising services;

n) innovative services;

o) financial transactions and/or financial service;

p) insurance service;

q) consulting, legal, accounting, audit and marketing services;

r) data processing and information support services;

s) service for preparing goods for sale, including breaking down of a consignment, forming for shipment, sorting, packing,

repacking, bottling;

t) service for storing goods or other property;

u) security service;

v) production of goods or other property with the client's raw materials (materials);

w) cargo-handling service, including forwarding, loading, unloading and transhipment services;

x) service for seagoing ships, including port service, port vessels service;

y) service for aircraft, including air navigation services provided in Georgian airports, airspace and cosmic space;

z) other services.

2. Production of goods with the client's raw materials (materials) shall be any production of goods, including preparation,

processing, treatment of goods or other transformation of the raw materials (materials), in the process of which the owner

of both the raw materials (materials) and of the final product is the person who supplied the raw materials (materials) and

paid, in cash or in kind, the cost of the service related to the production of goods with such raw materials (materials)

(irrespective of whether in the production of such goods the producer used its own raw materials (materials), component

or other parts, the cost of which was included in the cost of the service related to such production).

Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011

http://www.matsne.gov.ge 20000000005001016012

Law of Georgia No 5503 of 22 June 2016 – website, 12.7.2016

Article 15 – Financial instruments, financial transactions, financial services

1. A financial instrument shall be an agreement (contract) that gives rise to both financial asset of one person and

financial liability of another person. It shall include: funds (cash or non-cash), loans (credits), loan obligations, promissory

notes and securities, shares in capital, shares, bonds and such derivatives as: options, futures, forwards, swaps, etc.

Financial instruments shall also include any agreement between two entities (contracting parties) that is denominated in

money and permitted by the legislation of Georgia. At the same time, if goods and/or services, except for financial

transactions and supply of services, are supplied under that agreement or at any stage of the operation of that agreement,

between the holders of that financial instrument and/or for/from third persons, the agreement shall no longer be

considered a financial instrument after such supply.

2. The following shall be considered financial service/transaction:

a) opening, managing, closing any type of account (including current, settlement, deposit, brokerage, etc. accounts), as

well as using any payment instrument, including processing/executing transfer orders in the payment system, as well as

carrying out clearing and cash or non-cash settlements (including collection services);

b) circulation of financial instruments and cash or non-cash transactions relating to the circulation, as well as the use of

any payment instrument;

c) obtaining/issuing/transferring, syndicating, structuring, managing and using a credit (loan), including actions taken to

secure a credit (loan) (pledging property/assets, re-selling the credit risk to a third person in whole or in part,

issuing/certifying/managing/using guarantees or similar financial instruments or acquiring/being the beneficiary of such

instruments), credit (loan) servicing (payment of interest and principal), factoring, and receiving interest and credit

(principal) payments on a credit (loan);

d) transactions related to the issue, acquisition, circulation and/or supply (including in the future) of shares in capital,

shares, bonds, certificates, promissory notes and other securities, including transactions carried out to ensure their

circulation;

e) issue of funds, securities and/or other financial instruments, their management (including formation of pension and

investment funds or other collective or individual savings plans, and accumulation of financial instruments therein,

activities of the asset management company, insurer and pension company under the Law of Georgia on Voluntary

Private Pension), use, placement (including with the third persons on a guaranteed or non-guaranteed basis),

receipt/transfer into nominal holding, lending/borrowing on temporary (repo) basis, administration, including

registration (opening/maintenance of a register), transfer, blocking/unblocking, encumbering/releasing of encumbrance,

other depositary (including of a special depositary) and custodian (safekeeping and recording) transactions, establishing

their fair value, and issue/receipt/management of financial collaterals;

f) acting as a guarantor (including as a third party) for the transaction terms and settlements of financial instruments;

g) corporate transactions, in particular, splitting or consolidation of stocks and shares in capital, increase/reduction of

capital (including issuing, acquiring/alienating and circulating the right of participation in the increase of capital), merger

of two or more legal persons, division of a legal person into two or more legal entities, liquidation of a legal entity,

services related to accrual/accounting for and payment of dividends (in monetary or any other form allowed by law);

h) insurance and/or re-insurance, including the accompanying services provided by an insurance broker and/or an

insurance agent;

i) service of a payment service provider and a payment system operator in accordance with the Law of Georgia on

Payment System and Payment Service;

j) service directly linked with any financial service/transaction provided for in this paragraph.

3. (Deleted – 14.7.2020, No 6817).

4. In the case of a joint ownership (partnership) provided for by this Code, an owner’s interest in the joint ownership shall

be treated as a financial instrument if no property is attached to it or if the property is not registered in the owner’s name;

also, if the right to a property is registered in advance, the right shall be a financial instrument.

Law of Georgia No 6312 of 25 May 2012 – website, 12.6.2012

Law of Georgia No 5677 of 20 December 2019 – website, 31.12.2019

Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020

Law of Georgia No 3350 of 28 June 2023 – website, 19.7.2023

Article 16 – Supplying goods, delivering services

1. Transfer of title to goods to another person for consideration or free of charge (including sale or exchange of goods,

reimbursement by wages or in kind) shall be deemed as supply of goods.

2. Performance by a person of an action, which is not a supply of goods, for another person on his/her own will, for

consideration, or for free shall be considered provision of services.

Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020

Article 17 – (Deleted)

http://www.matsne.gov.ge 20000000005001016012

Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011

Article 18 – Principle of determining the price of goods/services

1. The actual price of goods/services in a transaction shall be used for taxation purposes, unless this Code provides for the

application of a market price or any other price.

2. The market price of goods/services shall be the price formed as a result of interaction of demand for and supply of

identical (in the absence of such – similar) goods/services on the market of goods/services and on the basis of a transaction

between the persons on the relevant market who are not related parties under Article 19 of this Code. The transaction

between related parties shall be taken into account only if the existence of related parties does not affect the results of the

transaction.

3. The market price of goods/services shall be determined on the basis of information on transactions made on the market

on identical (similar) goods/services at the moment of supply of these goods/services (in the absence of such, on the

calendar day closest to the moment of sale that precedes or follows, the moment of sale of such goods/services by

maximum 30 calendar days), including the information on the prices fixed at international and other exchanges.

4. The market of goods/services shall be the area of circulation of these goods/services that is determined by a

seller's/buyer's ability to sell/buy, without significant costs, goods/services in the territory nearest to the seller/buyer

within or outside the borders of Georgia.

5. If there is no transaction on identical (similar) goods/services on the market of goods/services or there is no supply of

such goods/services on that market, the market price of goods/services shall be determined by the prices established on

the basis of transactions concluded on identical (similar) goods/services on the calendar day closest to the moment of sale

of goods/services. The calendar day must precede or follow the moment of sale of such goods/services by maximum 30

calendar days.

6. Where the provisions of paragraphs 1 through 5 of this article cannot apply, the market price of goods/services shall be

established using methods for determining expenditure, possible sales price or receivable benefit.

7. Official sources of information on the market prices of goods/services, the database of the relevant government

authorities, the information submitted to tax authorities by taxpayers, as well as other reliable information shall be used

to calculate the market price of goods/services.

8. From 1 September 2007, when supplying natural gas under the Law of Georgia on Energy and Water Supply, the

market price for tax purposes shall be the price determined (including under the concluded agreement) by the

Government of Georgia.

9. Market price of goods/services may be wholesale or retail.

10. An exchange (barter) transaction on goods/services shall be regarded as the sale of goods/services at market price for

each party supplying goods/services, and for each recipient of goods/services an exchange (barter) transaction on

goods/services shall be regarded as the purchase of goods/services at the same market price.

11. A tax authority may apply a market price for taxation purposes, if:

a) a transaction is carried out between related parties except where the existence of related parties does not affect the

results of such transaction;

b) a tax authority proves, in the manner prescribed by the Minister of Finance of Georgia, that the price stated between

the parties to the transaction differs from the actual price;

c) a person delivers goods and/or services to a tourist zone entrepreneur.

12. Identical goods are various goods having similar characteristics, in including physical characteristics, quality,

reputation on market, country of origin and/or manufacturer.

13. Similar goods are various goods, which are not identical but have like characteristics and like component materials,

which enable them to perform the same functions and be commercially interchangeable.

14. For the purposes of paragraph 11(a) of this article, the Minister of Finance of Georgia may specify the cases, where the

existence of related parties does not affect the results of a transaction concluded between them.

15. For the purposes of the eleventh paragraph of this article, the existence of related parties shall be deemed not to have

affected the outcome of a transaction, if the supply of foreign goods between a special trading company and its related

party was performed in a customs warehouse at customs value.

Law of Georgia No 4061 of 15 December 2010 – LHG III, No 75, 27.12.2010, Art. 469

Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011

Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012

Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012

Law of Georgia No 5651 of 20 December 2019 – website, 27.12.2019

Article 19 – Related parties

1. Parties shall be regarded as related if the existence of a special relationship between them may affect the conditions or

economic results of their activity or the activity of the persons that they represent.

2. Special relationships shall be the relationships, where:

a) persons are the founders (participants) of one enterprise, provided their combined share is at least 20%;

http://www.matsne.gov.ge 20000000005001016012

b) one person has a direct or indirect interest in another person’s enterprise, provided such participation is at least 20%;

c) a person controls the enterprise;

d) a natural person is subordinated to another natural person;

e) one person directly or indirectly controls another person;

f) the persons are controlled, directly or indirectly, by a third person;

g) the persons jointly control, directly or indirectly, a third person;

h) the persons are relatives;

i) the persons are members of a partnership.

3. For the purposes of the tax legislation of Georgia, a natural person’s relatives shall be:

a) the first line of relatives: spouse, parent, child, sister, brother;

b) the second line of relatives: spouse, parent, child, sister, brother of each relative in the first line, except for the natural

person who already belongs to the first line;

c) persons who are related to one other as parents and children as a result of long-term guardianship.

4. In determining kinship, step sisters (brothers) shall be treated as equal to full sisters (brothers) and adoptees shall be

treated as equal to biological children. At the same time, guardianship relations shall be regarded as equal to a family

unity (where persons are related to one another as parents and children) which, in turn, shall be deemed equal to kinship

relationship. Termination of family unity between these persons shall not be taken into account if a parent-and-child

relationship between them is maintained under paragraph 3(c) of this article.

5. For the purposes of this article, control shall mean: a supervisory board membership, directorship and the right to

appoint persons to such offices; holding 20% of voting share or interest.

6. For the purposes of this article, a natural person shall be an indirect holder of the interest if his/her relative holds this

interest.

SECTION II

TAXPAYERS, TAX AGENTS, ENTERPRISES, ORGANISATIONS, NATURAL PERSONS

Chapter III – Natural Persons, Enterprises, Organisations

Article 20 – Taxpayers, tax agents

1. A taxpayer shall be a person who is obligated to pay taxes provided for by this Code.

2. A tax agent shall be a person who must fulfil a taxpayer's tax obligation in the cases and in the manner provided for by

this Code.

3. For the purposes of this Code, a tax agent shall be treated as equal to a taxpayer.

Article 21 – Enterprise

1. The following entities conducting or created to conduct economic activities shall be regarded as enterprises:

a) legal entities established under the legislation of Georgia;

b) corporations, companies, firms and similar entities established under the legislation of a foreign country, irrespective of

whether they have legal entity status, as well as a permanent establishment of a foreign enterprise.

c) associations, partnerships and similar entities not provided for in subparagraphs (a) and (b) of this paragraph.

2. An individual entrepreneur shall not be regarded as an enterprise.

Article 22 – Georgian enterprises and foreign enterprises

1. A Georgian enterprise shall be an enterprise whose place of business and/or management is based in Georgia.

2. A foreign enterprise shall be an enterprise that is not a Georgian enterprise under this article.

Article 23 – International company

1. An international company shall be an enterprise of Georgia, which performs activities defined by an ordinance of the

Government of Georgia and earns income solely from these activities.

2. The status of international company shall be granted to an entity by the Government of Georgia.

3. Performance by an international company of the activities not defined by an ordinance of the Government of Georgia

shall entail cancellation of the status of international company for it as of 1 January of the year the activities were

commenced.

4. An international company may not be set up within a Free Industrial Zone (FIZ).

5. (Deleted – 14.7.2020, No 6817).

6. (Deleted – 14.7.2020, No 6817).

7. The income earned as a result of working for hire at an international company shall be taxed at 5%.

8. A dividend paid by an international company shall not be taxed at the source and shall not be included in the gross

income of a person receiving the dividend.

9. The object of profit taxation for an international company shall be defined under Article 97(1) of this Code.

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10. The profit tax rate for an international company shall be 5%.

11. The amount of taxable profit of an international company shall be calculated by dividing the amount of payment

made/cost incurred according to the object of taxation by 0.95.

12. If the expenses defined by an ordinance of the Government of Georgia are borne in Georgia, an international company

may, under the procedure determined by the Minister of Finance of Georgia, reduce the sum subject to profit taxation by

the amount of the expenses.

13. An international company shall be exempt from property (except for land) tax if that property is intended or used for

the performance of activities allowed by the ordinance of the Government of Georgia.

14. The procedure for communicating information about employees to a tax authority, and for enjoying the privilege

provided for by paragraph 7 of this article shall be established by the Minister of Finance of Georgia.

15. The procedure for granting and cancelling the status of international company for an entity, and the types of activities

allowed for an international company shall be determined by the Government of Georgia.

Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016

Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019

Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020

Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023

23 1 – Investment funds

1. An investment fund shall be an enterprise established in accordance with the Law of Georgia on Investment Funds as a

joint investment fund or investment company.

2. On the basis of the Law of Georgia on Investment Funds, activities related to the management and administration of an

investment fund, and the provision of depositary services to an investment fund shall be deemed a financial service.

3. Profit and loss of a joint investment fund shall be deemed the profit and loss of each owner of a joint investment fund

unit beyond the joint investment fund, in proportion to the value of the unit (units) he/she owns. The loss assigned to the

owner of a joint investment fund unit on the basis of this paragraph must not exceed the amount of contribution he/she

has paid to the investment fund and the expenses and commission charges paid to an asset management company.

4. The asset management company of the joint investment fund shall open an investment account for each unit owner

under the procedure established by a joint order of the Ministry of Finance of Georgia and the National Bank of Georgia,

and shall keep records of the profit and loss of a unit owner.

5. Surplus income earned by the owner of a joint investment fund unit by selling or redeeming the unit shall be reduced

by as much as the surplus income included in the taxable income of the same unit owner on the basis of paragraph 3 of

this article.

6. Owners of joint investment fund units shall independently keep tax reports. The joint investment fund and its asset

management company shall not be liable to act as a tax agent provided for Article 154 of this Code.

7. Performance of the activity by an owner of a joint investment fund unit or on his/her behalf under the Law of Georgia

on Investment Funds shall not oblige this unit owner to have a permanent institution in Georgia.

8. The profit distributed by a joint investment fund within the activity defined by the Law of Georgia on Investment

Funds and the expenses/paid sums provided for by Article 97(1)(b-d) of this Code shall not be subject to profit taxation.

9. The dividend paid by an investment company to a natural person or a non-resident enterprise shall not be taxed at

source and shall not be included in the gross revenue of a recipient of income.

10. The expenses/paid sums provided for by Article 97(1)(b-d) of this Code envisaged by an investment company within

the activity defined by the Law of Georgia on Investment Funds shall be exempt from profit tax.

11. Distribution of profit by an investment company, if a recipient of dividend is a non-resident or a natural person, shall

be taxed in accordance with Article 97(1)(a) of this Code:

a) at a 15% rate, except as provided for in sub-paragraph b) of this paragraph;

b) at a 5% rate if the investment company makes an investment only in bank deposits and/or financial instruments, except

for the distribution of profit gained from a resident enterprise.

12. The distribution of profit by an investment company to a non-resident or a natural person shall be exempt from profit

tax if the income from which the dividend is paid:

a) does not belong to income received from a Georgian source;

b) belongs to income received by a resident legal person from the sale of the equity securities issued through a public

offering in Georgia and allowed for trading on an organised market recognised by the National Bank of Georgia;

c) belongs to income received by a resident legal person from the sale of the loan securities issued via a public offering in

Georgia and allowed for trading on an organised market recognised by the National Bank of Georgia, or to income earned

as an interest from the securities;

d) belongs to surplus income received from the sale of the loan securities issued by the Government of Georgia or an

international financial institution, or to income earned as an interest from the securities or from a deposit placed in a

banking institution of Georgia.

13. Surplus income received by a non-resident or a natural person through the supply or redemption of an investment

fund unit shall be taxed:

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a) at a 15% rate, except as provided for in sub-paragraph b) of this paragraph;

b) at a 5% rate if the investment fund makes an investment only in bank deposits and/or financial instruments, except

when the investment fund makes an investment in the equities/shares (holds equities/shares) of a resident enterprise.

14. The income shall be exempt from income and profit taxes if it is received:

a) from the sale of an investment fund unit issued through a public offering in Georgia and allowed for trading on an

organised market recognised by the National Bank of Georgia;

b) from the sale of an investment fund unit or the redemption of an investment fund unit if the investment fund makes an

investment only in the deposits placed in banking institutions of Georgia, in the securities issued by the Government of

Georgia and/or an international financial institution, and/or in the loan securities issued by a resident legal person

through a public offering in Georgia and allowed for trading on an organised market recognised by the National Bank of

Georgia.

15. For the identification of the profit sum exempt from profit tax under paragraph 12 of this article it shall be deemed

that, at the time of distribution of dividends by the investment company, this sum will be paid out in the first place.

16. For the purposes of paragraphs 2-15 of this article, each sub-fund of an umbrella fund provided for by the Law of

Georgia on Investment Funds shall be deemed an independent investment fund.

17. Apart from the grounds provided for by paragraphs 12 and 14 of this article, additional grounds for the exemption

from income or profit taxation shall be defined in accordance with the general rules established by this Code.

Law of Georgia No 6815 of 14 July 2020 – website, 22.7.2020

Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023

Article 24 – (Deleted)

Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011

Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011

Article 24 1 – Special trading company

1. A special trading company shall be a company that has been accorded the status of a special trading company under this

article in order to exempt it from profit tax.

2. The status of a special trading company may be accorded at the time of registration only to a company that is set up for

that purpose, for the current and following calendar years. When granting the status of a special trading company, a

certificate confirming the status shall be issued. A foreign enterprise conducting economic activity through a permanent

establishment in Georgia may additionally register a separate permanent establishment in order to acquire the status of a

special trading company and to conduct only those activities that are permitted by this article.

3. The status of a special trading company shall be accorded to an enterprise by a tax authority. The procedure for

according the status of a special trading company shall be determined by an order of the Minister of Finance of Georgia.

4. An enterprise having the status of a special trading company may:

a) re-export foreign goods from a customs warehouse;

b) supply foreign goods in a customs warehouse both to special trading companies and other enterprises that do not have

the status of a special trading company;

c) purchase foreign goods from enterprises that do not have a special trading company status at not less than their customs

value for subsequent re-export and/or supply in a customs warehouse;

d) in addition to the income earned from the activities referred to in subparagraphs (a) – (c) of this paragraph, earn other

income, including:

d.a) income that is exempt from profit tax under this Code;

d.b) income from the supply of fixed assets used by the special trading company for economic activity for over two years;

d.c) income, other than that referred to in subparagraphs (d.a) and (d.b) of this paragraph, which from a Georgian source,

according to a tax period (year) must not exceed GEL 1 000 000 and 5% of the customs value of the foreign goods brought

by such company into Georgia.

5. An enterprise having the status of a special trading company may not:

a) import goods into Georgia, other than goods intended as fixed assets of the company;

b) buy Georgian goods within the territory of Georgia for subsequent supply;

c) deliver services to a Georgian enterprise/individual entrepreneur and/or permanent establishment of a foreign

enterprise in Georgia;

d) have a customs warehouse.

6. If a taxpayer buys foreign goods from a special trading company, the costs deductible by the buyer from the total

annual income shall not exceed the customs value of such goods. That restriction shall not apply to the costs incurred by

the buyer, which under this Code are attributed to the value of the asset and are not related to the payments made to the

special trading company.

7. The status of a special trading company shall be cancelled for that calendar year which the authorised representative of

the company indicates in an application for cancellation of the status of a special trading company. The application has to

be submitted not later than five business days before commencement of the relevant year.

http://www.matsne.gov.ge 20000000005001016012

Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011

Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011

Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012

Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012

Article 24 2 – A special enterprise

1. A special enterprise shall be a person who has been granted the status of special enterprise under this article.

2. A person having the status of special enterprise may, along with the activities permitted by the legislation of Georgia,

with the special consent under Article 6(2) of the Law of Georgia on Occupied Territories, conduct the following

activities:

a) supply of goods originated or produced in the occupied territory of Georgia from the mentioned territory to another

territory of Georgia, and/or their placement under the export procedure from the territory of Georgia (except for the

occupied territory of Georgia), in accordance with law. In the case under this subparagraph, supply of excise goods

(except for alcoholic beverages and tobacco products) shall be prohibited;

b) supply of Georgian goods (except for goods originated or produced in the occupied territory of Georgia) to the occupied

territory of Georgia;

c) production of goods in the occupied territory of Georgia solely for the purpose under subparagraph a) of this paragraph.

3. The status of special enterprise shall be granted to a person by a tax authority.

4. A person having the status of special enterprise may supply the goods under paragraph 2(a) and (b) of this article only:

a) within/from the territory of the Autonomous Republic of Abkhazia – from/to Zugdidi municipality;

b) within/from the territory of Tskhinvali region (former Autonomous Region of South Ossetia) – from/to Gori

municipality.

5. Procedures for granting the status of special enterprise to and revoking it for a person, for identifying the goods

originated or produced in the occupied territory of Georgia, and the operating procedures for a person having this status

shall be determined by the Government of Georgia.

Law of Georgia No 2476 of 6 June 2018 – website, 21.6.2018

Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019

Article 25 – Free Industrial Zone Enterprise

1. A Free Industrial Zone Enterprise (‘FIZ Enterprise’) shall be a company established under the Law of Georgia on Free

Industrial Zones.

2. If a FIZ Enterprise supplies goods to a person (other than a FIZ Enterprise) registered under the legislation of Georgia,

the FIZ Enterprise shall pay 4% of the revenue received/receivable from the supply of such goods (if the supply of goods is

made free of charge – 4% of the market price of such goods) not later than the 15 th day of the month following the

month in which the goods are supplied.

3. If a person (other than a FIZ Enterprise) registered under the legislation of Georgia supplies goods (other than

electricity, water and natural gas intended for local consumption and/or production) to a FIZ Enterprise, the FIZ

Enterprise shall pay 4% of the market price of the supplied goods not later than the 15 th day of the month following the

month in which the goods are supplied.

4. If a person (other than a FIZ Enterprise) registered under the legislation of Georgia delivers goods to a FIZ Enterprise,

the market price of the supplied goods shall be used for taxation purposes.

5. A FIZ Enterprise may not:

a) purchase services from a person (other than a FIZ Company) registered under the legislation of Georgia, except for:

a.a) security services and/or services related to letting or leasing out property provided by an organiser and/or

administration of the Free Industrial Zone;

a.b) transport, communication, sewage, audit and/or consulting services, execution of financial transactions and/or

delivery of financial services by a licensed financial institutions, as well as services relating to installation, assembly

and/or construction of fixed assets.

a.c) services as determined by the Government of Georgia.

b) delivering services to a person (other than a FIZ Enterprise) registered under the legislation of Georgia.

6. Tax reporting rules for FIZ Enterprises shall be determined by an order of the Minister of Finance of Georgia.

7. The Government of Georgia shall be entitled to determine the types of services to be provided to non-resident persons

(except for permanent offices of non-resident persons in Georgia) by FIZ Enterprises, which, for the purposes of taxation,

shall be deemed as permitted activities carried out by FIZ Enterprises in the free industrial zone.

Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011

Law of Georgia No 6015 of 10 April 2012 – website, 30.4.2012

Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012

Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014

Law of Georgia No 4680 of 18 December 2015- website, 29.12.2015

http://www.matsne.gov.ge 20000000005001016012

Article 26 – (Deleted)

Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011

Law of Georgia No 6015 of 10 April 2012 – website, 30.4.2012

Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017

Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025

Article 26 1 – Tourist enterprise

1. A tourist enterprise shall be a legal person that builds a hotel, supplies hotel assets/part of the assets to another person

(with or without the right to buy back the assets), and on the basis of a commutative contract (including on the basis of a

lease, right of use, right of administration, trusteeship, intermediary and/or other contract terms) concluded with the

buyer of this property ensures that the hotel assets/ part of the assets are used as hotel rooms/apartments.

2. After the completion of the hotel construction, a tourist enterprise shall:

a) designate a fixed amount of space to be used for hotel rooms/apartments;

b) make sure that during a maximum of 10 calendar years after the acceptance of the building (hotel) for operation, the

total (including amounts additionally charged by the tax authority with respect to the given facility in the relevant

period) VAT taxable turnover (other than transactions exempt from VAT) from a specific facility (hotel) declared by a

tourist enterprise and/or by a person(s) invited under a relevant agreement for the functioning/operation of the

facility/part of the facility as a hotel, is not less than the amount obtained as a result of dividing the turnover exempt from

VAT with the right of deduction defined by Article 172(4)(v) of this Code as a result of supplying the hotel assets/part of

assets by 1.18.

3. The status of tourist enterprise shall be granted to a person by the Revenue Service according to a specific facility

(hotel). The Revenue Service may request the tourist enterprise to present guarantees, the value of which must not exceed

18% of the amount obtained as a result of dividing the turnover exempt from VAT with the right of deduction under

Article 172(4)(v) of this Code.

4. The procedure for awarding the status of a tourist enterprise to a person, the procedure for its operation and

cancellation, as well as the minimum amount of space from the total space of the building to be used as hotel

rooms/apartments according to the municipalities shall be determined by the Government of Georgia.

Law of Georgia No 5791 of 13 March 2012 – website, 23.3.2012

Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012

Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014

Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020

Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020

Article 26 2 – (Deleted)

Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017

Law of Georgia No 5627 of 19 December 2019 – website, 26.12.2019

Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025

Article 26 3 – Pharmaceutical enterprise

1. A pharmaceutical enterprise shall be a legal person producing and supplying pharmaceutical products in Georgia.

2. The status of pharmaceutical enterprise shall be granted to a person by the Government of Georgia.

3. The procedure for granting the status of pharmaceutical enterprise to a person, for operating and cancelling it shall be

defined by an ordinance of the Government of Georgia.

Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019

Article 27 – Place of business of an enterprise

1. A place of business of an enterprise shall be the place of its state registration, and in the absence of such place, the legal

address indicated in the founding documents (charter, agreement, regulations) of the enterprise.

2. If an enterprise conducts business without state registration and its founding documents do not specify a place of

business of the enterprise, the place of business of the enterprise shall be its principal place of business. The principal

place of business of an enterprise shall be determined by a tax authority on the basis of data submitted by the enterprise.

If the enterprise fails to submit such data or presents questionable data, a tax authority shall determine the principal place

of business of the enterprise on the basis of available information.

3. If no relevant information is available and the principal place of business of an enterprise cannot be determined, the

place of business of an enterprise shall be the place of management of the enterprise.

4. The place of business of an enterprise provided for in Article 21(1)(c) of this Code shall be the place of business of the

party to the agreement who is responsible for managing the business affairs under the joint activities agreement. If one of

the parties to an agreement is a Georgian enterprise or a resident natural person, that party shall keep record of the results

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of the joint activities for taxation purposes, irrespective of who is responsible for managing the business affairs. If business

affairs are not managed by one or several parties to the joint activities agreement but rather jointly by all the parties to the

agreement, the place of business of the enterprise shall be the place of business of the Georgian enterprise participating in

the joint activities agreement. If the parties to the joint activities agreement are only resident natural persons who jointly

run the business, the place of business of the enterprise shall be determined by a tax authority on the basis of data

presented by the parties to the joint activities agreement. If the parties to the joint activities agreement do not submit

such data or present questionable data, a tax authority shall determine the place of business on the basis of available

information.

Article 28 – Place of management of an enterprise

1. The place of management of an enterprise shall be place of effective management of the enterprise, i.e. the place where,

under the founding documents (charter, agreement, regulations) of the enterprise, the board of directors (or any other

management body) of the enterprise exercises managerial functions irrespective of the place of business of the enterprise’s

top controlling bodies or the place of receipt of income from its activities, unless otherwise provided for in this article.

2. The place of management of an enterprise provided for in Article 21(1)(c) of this Code shall be the place of business of

the enterprise.

3. If an enterprise is managed by a manager (another enterprise or natural person) who acts under an agreement or

resolution of appointment, the place of management of the enterprise shall be the place of business of the managing

enterprise or the place of residence of the managing natural person, respectively. The place of management of an

enterprise shall be determined similarly if the enterprise is actually managed by another enterprise or natural person

without a relevant agreement or resolution.

4. If an enterprise has no management body or the management body of an enterprise has no permanent place of business

or if the manager does not directly manage the enterprise, the place of management of the enterprise shall be the place of

business of the management body (administration, directorate, board of directors, central accounting office or other

similar body) of the enterprise.

Article 29 – Permanent establishment

1. A permanent establishment of a foreign enterprise or of a non-resident natural person in Georgia is a fixed place of

business through which the economic activity of the entity is wholly or partly carried on in Georgia, including the

activity of an authorised agent, except as provided for by the sixth, ninth and twelfth paragraphs of this article.

2. The following shall be treated as equal to a permanent establishment:

a) a construction site, installation or construction project and the controlling activities related to them;

b) installation or constructions, drilling rig or vessels used for prospecting minerals, and the controlling activities related

to them;

c) a permanent base where a non-resident natural person carries on economic activity;

d) a place of management, branch, representative office, department, bureau, office, agency, workshop, mine or quarry or

any other place of extraction of natural resources, or any other subunit or any other place of business of a foreign

enterprise.

3. The provisions of the first and second paragraphs of this article shall not apply to the services rendered by non-resident

subcontractors in performing oil and gas operations under the Law of Georgia on Oil and Gas.

4. Notwithstanding the provisions of the first and second paragraphs of this article, a permanent establishment of a

foreign enterprise in Georgia shall be the management of this enterprise by another person (another enterprise, subunit of

this or of another enterprise or by a natural person who is not the person specified in the fifth paragraph of this article) on

behalf and/or in the interest of the enterprise for over three months, except as provided for in the sixth and fifth

paragraphs of this article.

5. If a foreign enterprise or a non-resident natural person carries on economic activity in Georgia through a professional

intermediary, agent or broker as prescribed by law and if such intermediary, agent or broker is not authorised to conduct

negotiations or sign agreements on behalf of the foreign enterprise or non-resident natural person, then the activity of the

intermediary, agent or broker shall not constitute a permanent establishment of the foreign enterprise or non-resident

natural person in Georgia.

6. Mere possession by a foreign enterprise or non-resident natural person of securities or shares in the capital of a

Georgian enterprise or of any property on the territory of Georgia shall not constitute a permanent establishment of the

foreign enterprise or non-resident natural person in Georgia if such possession does not have the characteristics of a

permanent establishment set forth in the first and second paragraphs of this article.

7. The mere fact of secondment of staff by a foreign enterprise to another enterprise or organisation based in the territory

of Georgia shall not constitute a permanent establishment of the foreign enterprise or non-resident natural person in

Georgia, provided that the employees are under the control of the enterprise or organisation to which they were

seconded.

8. The mere control by a foreign enterprise or non-resident natural person of a Georgian enterprise or a Georgian

organisation shall not constitute a permanent establishment of the foreign enterprise or non-resident natural person in

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Georgia.

9. A permanent establishment of a foreign enterprise or non-resident natural person in Georgia shall not include an

establishment in the territory of Georgia that is used only for:

a) storing or displaying goods belonging to the foreign enterprise or non-resident natural person;

b) storing a stock of goods belonging to the foreign enterprise or non-resident natural person so that another person could

process it;

c) purchasing goods or gathering information for the foreign enterprise or non-resident natural person;

d) performing preparatory or any other ancillary activity in the interests of the foreign enterprise or non-resident natural

person;

e) preparing and/or signing agreements on granting loans, supplying goods or providing technical services on behalf of the

foreign enterprise or non-resident natural person.

f) conducting any combination of the activities set forth in subparagraphs (a)-(e) of this paragraph.

10. A permanent establishment of a foreign enterprise or of a non-resident natural person in Georgia shall be deemed as

such from the moment when it is registered under the eleventh paragraph of this article, is granted appropriate powers or

commences representative activity.

11. The obligation to register a permanent establishment of a foreign enterprise or of a non-resident natural person in

Georgia shall rest with a tax authority, which shall maintain the relevant register. The registration procedure and the

procedure for maintaining the register shall be determined by the Minister of Finance of Georgia.

12. The mere transfer of property by a foreign enterprise or non-resident natural in the territory of Georgia by lease,

usufruct, rent, letting and/or any other similar form shall not constitute a permanent establishment of this foreign

enterprise or non-resident natural person in Georgia, except where a person systematically performs, in person, through a

representative or hired personnel, the service and supervision of the activities of the property recipient.

Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011

Article 30 – Organisations

1. The following entities shall be regarded as organisations:

a) non-entrepreneurial (non-commercial) legal persons, public or religious organisations (associations), institutions that

are non-entrepreneurial (non-commercial) legal persons established or acting under the legislation of Georgia or under

the legislation of a foreign country; also Georgian-based branches and other similar sub-units of the organisations

established under the legislation of a foreign country, through which these organisations conduct business, wholly or

partly, (including the activity of an authorised agent), also budgetary organisations, legal entities under public law,

corporations, institutions;

b) international (inter-state, inter-governmental, diplomatic) organisations – organisations, diplomatic missions and

consular offices, or foreign non-entrepreneurial organisations governed by international law.

2. A place of business and a place of management of an organisation shall be determined according to procedures

established for enterprises by this Code.

3. An organisation shall be deemed as a Georgian organisation or as a foreign organisation according to procedures

established for enterprises by this Code.

4. If an organisation conducts economic activity, the part of its property and activity that is directly related to its

economic activity shall be deemed to be the property and activity of the enterprise, and where such distinction cannot be

made, the property and activity related to the economic activity of an organisation shall be calculated according to the

specific share of the income from economic activity in the income earned by the organisation.

Law of Georgia No 6439 of 12 June 2012 – website, 22.6.2012

Article 31 – Budgetary organisations

A budgetary organisation is an organisation defined in Article 6(r) of the Budget Code of Georgia.

Law of Georgia No 5173 of 28 October 2011 – website, 7.11.2011

Law of Georgia No 2938 of 12 December 2014 – website, 24.12.2014

Article 32 – Charitable organisations

1. A charitable organisation shall be an organisation that has been accorded with the status of a charitable organisation

under this article.

2. The status of a charitable organisation shall be accorded to an organisation that is established to carry out charitable

activity, is registered in a prescribed manner, has at least one year experience in charitable activity and complies with the

requirements set forth in this article.

3. Ancillary economic activity that serves the main purposes of an organisation shall not change the organisation’s

charitable character.

4. The status of a charitable organisation is accorded, cancelled and deprived by the Head of the Revenue Service in

agreement with the Minister of Finance of Georgia upon a recommendation of the relevant tax authority.

5. The status of a charitable organisation is accorded on the basis of a written application of the organisation. The

http://www.matsne.gov.ge 20000000005001016012

application shall indicate the following information on the organisation:

a) name;

b) organisational and legal form;

c) main goals;

d) main areas of activity in the last year;

e) addresses of the management body and of branches.

6. The following shall be attached to the application:

a) a copy of the charter of the organisation

b) a copy of the civil and/or tax registration certificate

c) an activity report for the last year, including the description of activities (projects, services)

d) the last year’s financial documents (balance sheet and income statement) certified by an independent auditor.

7. The Head of the Revenue Service shall make a reasonable decision in connection with the application within one

month. If no decision is made within this period, the status shall be deemed to have been accorded. The status shall be

accorded permanently. The status shall take effect upon being accorded.

8. An organisation that has been accorded with this status shall be given a certificate confirming the status. The certificate

shall indicate:

a) name and organisational and legal form of the organisation

b) status

c) address of the management body

d) date of according the status and the status number

e) identification number of the organisation.

9. Upon obtaining the status, the organisation shall undertake the obligations and responsibilities provided under this

Code. In particular, before 1 April each year a charitable organisation shall file with the relevant tax authority:

a) a program report on its last year's activity, which shall include a description of the activity (including economic

activity);

b) a financial report on earned revenues, indicating sources and the purpose of the expenditure;

c) last year’s financial documents (balance sheet and income statement) certified by an independent auditor.

10. The program report of the last year's activity and last year’s financial documents (balance sheet and income statement)

shall be published and made available for all interested persons.

11. The profits and assets of a charitable organisation shall not be distributed among its members, founders, board of

directors or supervisory board members. If a charitable organisation is liquidated, its property shall be transferred to a

charitable organisation with similar goals under a decision of an authorised body or person, or if no such organisation

exists, the property shall be transferred to another charitable organisation. If a legal entity under public law having the

status of a charitable organisation was established on the basis of state property, in the case of its liquidation its assets shall

be transferred to the state.

12. The status of a charitable organisation shall be cancelled:

a) on the initiative of the organisation;

b) if the status has been deprived.

13. A charitable organisation shall be deprived of its status if:

a) it fails to comply with the requirements of this Code;

b) its state and/or tax registration has been cancelled.

14. If the status is deprived for non-compliance with the requirements of this Code, the charitable organisation shall

return that part of profits received as a result of tax privileges due to the status, which is related to non-compliance with

the above requirements.

15. If a charitable organisation does not comply with the requirements of this Code, before submitting to the Revenue

Service an application for depriving the charitable organisation of its status, a tax authority shall send the charitable

organisation a notice, setting an additional one-month period for the fulfilment of the requirements of this Code.

16. A charitable organisation that has been deprived of its status may apply for restoration of the status not earlier than

one year after eliminating the cause for deprivation of the status.

17. The Revenue Service shall maintain the Unified Register of Charitable Organisations. The Register shall specify:

a) name of the organisation;

b) addresses of the management body, branches and representations;

c) main goals;

d) date of according the status and the status number;

e) identities and addresses of all members of the management body.

18. If any of the data entered into the Unified Register of Charitable Organisations is changed, the organisation shall

notify the relevant tax authority in writing of such changes as soon as they occur.

19. The Unified Register of Charitable Organisations shall be available for any interested person.

Article 33 – Religious organisations

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A religious organisation shall be an organisation established for conducting religious activity and registered as such in the

prescribed manner.

Article 34 – Resident natural persons and non-resident natural persons in Georgia

1. Natural persons shall be:

a) citizens of Georgia;

b) foreign citizens;

c) stateless persons.

2. A Georgian resident for the entire current tax year shall be a natural person who has actually stayed in the territory of

Georgia for 183 or more days in any continuous 12-calendar-month period ending in that tax year, or a natural person

who was in a foreign country in the public service of Georgia during that tax year.

3. The time of actual stay in the territory of Georgia shall be the time, during which a natural person stayed in Georgia, as

well as the time he/she spent outside Georgia specifically for treatment, leisure, business trip or education.

4. The time of actual stay in the territory of Georgia shall not include the time, during which a natural person stayed in

Georgia:

a) as a person having a diplomatic or consular status or as a family member of such person;

b) as an employee of an international organisation acting under an international agreement of Georgia or as a person in

the public service of a foreign country in Georgia or as a family member of such person, other than Georgian citizens;

c) when moving from one foreign country to another via the territory of Georgia;

d) for treatment or leisure.

5. The day of actual stay in the territory of Georgia shall be the day, during which a natural person stayed in Georgia

irrespective of the length of the stay.

6. Georgian residency, except as provided for in paragraph 2 of this article, may be accorded to a high net worth

individual under the procedure and conditions determined by the Minister of Finance of Georgia. A high net worth

individual shall be a person as defined by the Law of Georgia on Securities Market.

6 1 . If the residency of a natural person cannot be established in relation to any country, such natural person shall be

deemed to be a Georgian resident if he/she applies to a tax authority, provided he/she is a Georgian citizen.

6 2 . The residency of Georgia, except for cases provided for in paragraphs 2, 6 and 6 1 of this article, may be granted to a

foreign natural person in the case and under the procedure defined by the Minister of Finance of Georgia.

7. A non-resident in Georgia shall be a person who is not a resident under this article.

8. The status of a resident or of a non-resident is established for each tax period. At the same time, the days, according to

which the natural person was deemed as a resident in the previous tax period, shall not be taken into account in

establishing the status of residency in the following tax periods.

Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011

Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017

Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020

Article 35 – Place of residence and place of actual stay of a natural person

1. A place of residence of a natural person shall be the person’s usual place of residence or the place of his/her actual stay

unless otherwise provided for by this article.

2. A place of residence of a minor shall be the place of residence of the person having parental rights with respect to the

minor, and a place of residence of the person who has a guardian or custodian shall be the place of residence of the

guardian or custodian.

3. A place of actual stay of a natural person shall be the place of his/her temporary residence, unless otherwise provided

for in this article.

4. A place of actual stay of military personnel, also of persons permanently relocating due to the nature or conditions of

their job shall be the place where they actually live or are registered in the prescribed manner (including, the place of

deployment of military units or the location of the respective enterprise).

5. If a natural person has several residences (homes or other residence), his/her place of residence or place of actual stay

shall be determined by a tax authority in agreement with the natural person.

Article 36 – Entrepreneur natural person and his/her place of business

1. The following persons shall be deemed an entrepreneur natural person:

a) an individual entrepreneur – a natural person if he/she is an individual entrepreneur under the Law of Georgia on

Entrepreneurs;

b) a natural person if he/she is engaged in an activity provided for by Article 3(1 and 2) of the Law of Georgia on

Entrepreneurs.

2. If the natural person defined in the first paragraph of this article performs economic activity without registration,

license or permit, this shall not serve as the basis for not recognising this natural person as an entrepreneur natural person

for taxation purposes.

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3. The place of business of an entrepreneur natural person shall be the place of his/her economic activity.

Law of Georgia No 884 of 2 August 2021 – website, 4.8.2021

Article 37 – Taxpayer’s representative

1. A taxpayer may participate in tax matters through its legal or authorised representative. Personal participation of a

taxpayer in tax matters shall not deprive it of the right to have a representative, nor shall the participation of the

representative deprive it of the right to personally participate in the said relations.

2. Legal representatives of an enterprise/organisation shall be its bodies and/or other authorised persons under the

legislative acts of Georgia or foundation documents of the enterprise/organisation. A legal representative of a natural

person shall be the person who exercises relevant rights under this Code and other legislative acts of Georgia.

3. An action of a taxpayer’s legal representative, in particular the participation of the representative in tax matters, shall

be deemed the action of the taxpayer.

4. A taxpayer’s legal representative shall be a person who is authorised by the taxpayer to represent its interests before tax

authorities and/or in dealings with other participants of tax matters or in court.

5. An authorised representative of an enterprise/organisation shall act under a power of attorney granted by that

enterprise/organisation, and the authorised representative of a natural person shall act under a notarised power of

attorney granted by that natural person or under any other document deemed equal to a power of attorney under the

Civil Code of Georgia, within the scope of such power of attorney or other document.

Chapter IV – Legal Protection of Taxpayers

Article 38 – Right to request information

1. Taxpayers may obtain from tax authorities information on the application of the tax legislation of Georgia, on

protection of taxpayer’s rights, and may access information on them in the possession of tax authorities.

2. Taxpayers may withhold from law-enforcement and other controlling authorities, other than tax authorities,

documents related to the determination of objects of taxation, computation and payment of taxes, except where such

powers are granted to other authorities under this Code.

Article 39 – Tax secret

1. Any information received by a tax authority on a taxpayer (except for the information specified in paragraph 1 1 of this

article) shall be the tax secret.

1 1 . The following information on a tax payer shall not be a tax secret and shall be public:

a) information on registration as a tax payer;

b) information on registration as a VAT payer;

c) the status;

d) the name;

e) legal form;

f) the address;

g) the identification number;

h) the date of granting the identification number;

i) the registering body;

j) tax arrears;

k) the persons with the right of representation/administration;

l) the founders;

m) information on the tax lien/the right of pledge and on the seizure of property;

n) other public information registered in the Registry of Entrepreneurs and Non-Entrepreneurial (Non-Commercial)

Legal Entities;

o) public information registered in the Registry of Citizens’ Political Unions (Parties);

p) about the restriction of using (including the suspension of making out/issuing) a tax invoice for a person.

2. A tax authority, its employee, invited expert and/or expert shall protect the confidentiality of taxpayer information that

became known to them in the performance of official duties. They may disclose personally identifiable information on

certain taxpayers only to the following persons:

a) employees of the system of the Ministry of Finance of Georgia and members of the Council of Tax Appeals within the

Ministry of Finance of Georgia – in order for them to fulfil their official duties;

b) law-enforcement authorities – in connection with the criminal cases prosecuted by them;

b 1 ) (Deleted – 17.12.2025, No 1296);

b 2 ) the Ministry of Internal Affairs of Georgia – for exercising powers provided for by the legislation of Georgia;

c) court – to determine tax obligations or liabilities of a taxpayer in connection with a case pending in the court;

d) a competent body of a foreign state – under an international agreement of Georgia;

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e) the Legal Entity Under Public Law (LEPL) within the Ministry of Justice of Georgia – National Bureau of Enforcement)

(‘National Bureau of Enforcement’) and to a private enforcement officer – in the course of executing decisions under the

Law of Georgia on Enforcement Proceedings and/or in exercising the powers provided for in an agreement between a tax

authority and National Bureau of Enforcement;

f) the National Statistics Office of Georgia (GeoStat) – under procedures established by the Government of Georgia;

g) the State Audit Office, in performing inspection provided for by the Law of Georgia on Personal Data Protection, and

on the basis of a court order, for exercising the powers established by the Organic Law of Georgia on State Audit Office;

h) the Legal Entity under Public Law (LEPL) within the Ministry of Justice of Georgia – National Agency of Public

Registry (‘National Agency of Public Registry’) – in exercising the powers under an agreement between a tax authority

and the National Agency of Public Registry;

i) persons determined by the Government of Georgia, to inform a taxpayer of its tax arrears as prescribed by the Minister

of Finance of Georgia;

j) (Deleted – 1.5.2015, No 3581);

k) the Legal Entity under Public Law (LEPL) within the Ministry of Justice of Georgia – Public Service Development

Agency – in exercising powers provided for by the legislation of Georgia;

l) the Legal Entity under Public Law (LEPL) – Financial Monitoring Service of Georgia – in exercising powers provided

for by the legislation of Georgia;

m) the state sub-agency institution of the Ministry of Environment and Agriculture of Georgia – the Environmental

Supervision Department, in exercising powers provided for under the legislation of Georgia; also, to the Legal Entity

under Public Law (LEPL) within the Ministry of Environment and Agriculture of Georgia – the Nuclear and Radiation

Safety Agency, and to the Standing Commission for Military-Technical Issues of the Ministry of Defence of Georgia – the

information provided for under the Law of Georgia on Nuclear and Radiation Safety;

m) the state sub-agency institution of the Ministry of Environment and Agriculture of Georgia – the Environmental

Supervision Department, in exercising powers provided for under the legislation of Georgia; also, to the Legal Entity

under Public Law (LEPL) within the Ministry of Environment and Agriculture of Georgia – the Nuclear and Radiation

Safety Agency, and to the Standing Commission for Military-Technical Issues of the Ministry of Defence of Georgia – the

information provided for under the Law of Georgia on Radiation Protection, Nuclear Safety and Security;

n) the Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs of

Georgia and to administrative bodies within its system – for exercising the rights and duties under the legislation of

Georgia;

o) the Legal Entity under Public Law (LEPL) – the Georgian Competition and Consumer Agency – in exercising powers

provided for by the legislation of Georgia;

p) the Legal Entity under Public Law (LEPL) within the Ministry of Environment and Agriculture of Georgia – the

National Food Agency – under the procedure prescribed by the Government of Georgia;

q) (Deleted – 17.12.2025, No 1282);

r) the Legal Entity under Public Law operating under the Ministry of Justice of Georgia – the Digital Governance Agency

– in order for the Agency to forward the said information to the State Audit Office, for exercising powers under the Law

of Georgia on the Fight against Corruption and subordinate legal acts issued on its basis, for operating the electronic data

exchange system;

s) the Legal Entity under Public Law operating under the Ministry of Justice of Georgia – the Digital Governance Agency

– information necessary for the operation of the electronic exchange system of documentation between the entities

engaged in the international commerce;

t) the Ministry of Environment and Agriculture of Georgia, information under the Law of Georgia on Waste Import,

Export and Transit;

u) (Deleted – 5.7.2018, No 3109);

v) the Legal Entity under Public Law within the Ministry of Environmental Protection and Agriculture of Georgia – the

National Agency for Mineral Resources, in exercising powers defined by the legislation of Georgia;

w) the Legal Entity under Public Law – the Pension Fund of Georgia, for exercising powers under the Law of Georgia on

Funded Pension and subordinate normative acts of Georgia issued on the basis thereof;

w 1 ) the Legal Entity under Public Law – the Insurance State Supervision Service of Georgia, for exercising powers under

the Law of Georgia on Voluntary Private Pension and subordinate normative acts of Georgia issued on the basis thereof;

w 2 ) the insurer, the asset management company and the pension company defined by the Law of Georgia on Voluntary

Private Pension, for exercising powers under the same law and subordinate normative acts of Georgia issued on the basis

thereof;

x) the Legal Entity under Public Law within the system of the Ministry of Economics and Sustainable Development of

Georgia – the Market Surveillance Agency, in exercising the power under the legislation of Georgia;

y) the Ministry of Justice of Georgia, for exercising the power of an agent of the state, as vested in it by the legislation of

Georgia, in the arbitration or a foreign court, and the power of an agent of the state in an international court, in particular

in the European Court of Human Rights, in the Human Rights Committee set up on the basis of the United Nations

International Covenant on Civil and Political Rights and in the committees set up on the basis of other United Nations

http://www.matsne.gov.ge 20000000005001016012

conventions, and in the United Nations International Court of Justice;

z) to ensure control of the legal regime of the Georgian maritime space, the Joint Maritime Operations Centre of the

executive authorities of Georgia related to the protection of the national border control entities and the national

boundary regime, in exercising the power defined by the legislation of Georgia;

z1) the Legal Entity under Public Law (LEPL) subject to the control of the Ministry of Internally Displaced Persons from

the Occupied Territories, Labour, Health and Social Affairs of Georgia – the Labour Inspection Service, in exercising

powers provided for by the legislation of Georgia;

z2) the Legal Entity under Public Law (LEPL) within the system of the Ministry of Economy and Sustainable

Development of Georgia – the Land Transport Agency, in exercising powers provided for by the legislation of Georgia;

z2 1 ) a structural unit of the city hall, a natural person or a legal entity defined by a representative body of Tbilisi

municipality, for considering administrative offence cases provided for by Article 135 2 of Administrative Offences Code

of Georgia;

[z3) the Legal Entity under Public Law (LEPL) – the State Procurement Agency, in exercising powers provided for by the

Law of Georgia on Public Procurement;

z4) the Public Procurement-related Dispute Resolution Council – in exercising powers provided for by the Law of

Georgia on Public Procurement. (Shall become effective from 1 January 2030)]

z5) in accordance with the rule defined by an ordinance of the Government of Georgia, a property rights collective

management organisation defined by Article 63(2) of the Law of Georgia on Copyright and Related Rights, which has the

authority under Article 21(3) of the same Law and acts in compliance with the ordinance of the Government of Georgia.

z6) the Administration of the Government of Georgia, for fulfilling the function of facilitating control of the

implementation of decisions provided for by the Law of Georgia on the Structure, Powers and Procedure for Activity of

the Government of Georgia.

z7) the Ministry of Defence of Georgia, for controlling the compliance with the terms and conditions of the permit

provided for by the Laws of Georgia on Arms, on the Control of Military and Dual-use Goods and on Licences and

Permits, within the scope of its competence.

3. Employees of a tax authority shall protect the confidentiality of information obtained in the course of their official

duties, and shall not use it for personal goals or disclose it to another person. Such actions shall be regarded as disclosure

of a tax secret. The loss of documents containing a tax secret or disclosure of such information shall carry liability under

the legislation of Georgia.

3 1 . Legal entities under public law referred to in paragraph 2(o) and (p) of this article and their employees, who have

received information specified in this article may not divulge such information.

4. Information held by a tax authority and containing a tax secret shall be stored and processed in a special manner. Only

authorised officials designated by the Minister of Finance of Georgia under the procedure established by the same

ministry may have access to the information containing a tax secret.

5. If there is a written/electronic permission of a taxpayer, information on the taxpayer may be communicated to another

person. Publication and/or dissemination by the taxpayer of this information in the mass media shall be deemed as the

taxpayer’s permission for a tax authority to communicate information to a third party within the scope of the above

information.

6. This article shall not apply to the public notice provided for in Article 44 of this Code or the information spread by the

Revenue Service about persons who conduct economic activity with false tax documents.

Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011

Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011

Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011

Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012

Law of Georgia No 6330 of 25 May 2012 – website, 8.6.2012

Law of Georgia No 6317 of 25 May 2012 – website, 19.6.2012

Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012

Law of Georgia No 6444 of 12 June 2012 – website, 25.6.2012

Law of Georgia No 6550 of 22 June 2012 – website, 29.6.2012

Law of Georgia No 491 of 25 March 2013 – website, 5.4.2013

Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013

Law of Georgia No 2160 of 21 March 2014 – website, 27.3.2014

Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015

Law of Georgia No 3613 of 28 May 2015 – website, 4.6.2015

Law of Georgia No 3673 of 29 May 2015 – website, 4.6.2015

Law of Georgia No 4368 of 27 October 2015 – website, 11.11.2015

Law of Georgia No 4458 of 28 October 2015 – website, 11.11.2015

Law of Georgia No 4493 of 11 November 2015 – website, 24.11.2015

Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015

http://www.matsne.gov.ge 20000000005001016012

Law of Georgia No 4958 of 13 April 2016 – website, 26.4.2016

Law of Georgia No 5144 of 27 May 2016 – website, 4.6.2016

Law of Georgia No 195 of 22 December 2016 – website, 29.12.2016

Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017

Law of Georgia No 1701 of 7 December 2017 – website, 14.12.2017

Law of Georgia No 3109 of 5 July 2018 – website, 11.7.2018

Law of Georgia No 3308 of 21 July 2018 – website, 6.8.2018

Law of Georgia No 3279 of 21 July 2018 – website, 9.8.2018

Law of Georgia No 3383 of 5 September 2018 – website, 24.9.2018

Law of Georgia No 4260 of 27 December 2018 – website, 29.12.2018

Law of Georgia No 4599 of 8 May 2019 – website, 8.5.2019

Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019

Law of Georgia No 5691 of 20 December 2019 – website, 26.12.2019

Law of Georgia No 5758 of 17 March 2020 – website, 23.3.2020

Law of Georgia No 6301 of 12 June 2020 – website, 26.6.2020

Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020

Law of Georgia No 7132 of 16 September 2020 – website, 21.9.2020

Law of Georgia No 7183 of 29 September 2020 – website, 5.10.2020

Law of Georgia No 1148 of 16 December 2021 – website, 27.12.2021

Law of Georgia No 1331 of 30 December 2021 – website, 13.1.2022

Law of Georgia No 1384 of 16 February 2022 – website, 23.2.2022

Law of Georgia No 2214 of 30 November 2022 – website, 15.12.2022

Law of Georgia No 2285 of 1 December 2022 – website, 15.12.2022

Law of Georgia No 2578 of 9 February 2023 – website, 27.02.2023

Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023

Law of Georgia No 3290 of 16 June 2023 – website, 6.7.2023

Law of Georgia No 3350 of 28 June 2023 – website, 19.7.2023

Law of Georgia No 3759 of 29 November 2023 – website, 11.12.2023

Law of Georgia No 3865 of 15 December 2023 – website, 25.12.2023

Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023

Law of Georgia No 4324 of 27 June 2024 – website, 12.7.2024

Law of Georgia No 4427 of 5 September 2024 – website, 23.9.2024

Law of Georgia No 561 of 13 May 2025 – website, 16.5.2025

Law of Georgia No 1055 of 12 November 2025 – website, 17.11.2025

Law of Georgia No 1074 of 25 November 2025 – website, 27.11.2025

Law of Georgia No 1282 of 17 December 2025 – website, 18.12.2025

Law of Georgia No 1296 of 17 December 2025 – website, 23.12.2025

Law of Georgia No 1713 of 10 June 2026 – website, 15.6.2026

Article 40 – (Deleted)

Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013

Article 41 – Taxpayer rights

1. Taxpayers may:

a) in the prescribed manner, become familiar with information held by a tax authority about them;

b) represent their interests before a tax authority directly or through a representative;

c) not present any documents related to tax administration to any controlling or law-enforcement body (other than a tax

authority), unless such body has authority under this Code;

d) enjoy tax privileges;

e) obtain a refund for the sum of any overpaid tax and/or sanction (including a customs sanction), and/or keep it as a

credit against future tax liabilities;

f) request information about the grounds for exercising tax control over them;

g) provide appropriate explanations to a tax authority when subjected to a tax control;

h) attend tax field audits conducted in relation to them, receive from a tax authority original or certified copies of any

decision pertaining to them, and demand compliance with the legislation of Georgia during these activities;

i) appeal actions or decisions of a tax authority as provided by law;

j) not fulfil an illegal act issued or request made by a tax authority;

k) demand reimbursement of damages incurred as a result of unlawful decisions or action of a tax authority;

l) enjoy any other rights under the legislation of Georgia.

2. Protection of taxpayer rights and legitimate interests shall be guaranteed in administrative and judicial proceedings.

http://www.matsne.gov.ge 20000000005001016012

3. Violation of taxpayer rights and legitimate interests shall carry liability as prescribed by law.

Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011

Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013

Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019

Article 42 – (Deleted)

Law of Georgia No 3613 of 28 May 2015 – website, 4.6.2015

Article 43 – Taxpayer obligations

1. Taxpayers shall:

a) fulfil tax liabilities in accordance with the tax legislation of Georgia;

b) be enrolled with a respective tax authority or register with the Register of Entrepreneurs and Non-entrepreneurial

(Non-commercial) Legal Entities and the Register of Citizens’ Political Alliances (Parties);

c) file tax returns, computations, and accounting documents with a tax authority as provided by the legislation of Georgia;

d) submit to a tax authority and its authorised person the documents (certificates) needed for computation and payment of

taxes in the case of a tax audit or in any other cases provided for by this Code;

e) comply with the lawful requests of a tax authority and authorised persons with respect to the elimination of detected

violations of tax legislation; not prevent authorised persons from fulfilling their official duties;

f) ensure the safekeeping of documents necessary for identifying a taxable object for three years. Such period shall be

calculated from the end of the calendar year of relevant tax period, for the identification of tax liabilities of which such

documentation is necessary.

g) place a copy of a taxpayer certificate and in the case of retail trade – price labels (in Georgian national currency) at a

place conspicuous for customers;

g 1 ) not impede a person chosen by the Revenue Service under the legislation of Georgia in delivering services related to

affixing mandatory excise stamps/mandatory markings.

h) fulfil any other obligations provided for by the tax legislation of Georgia.

2. A Georgian enterprise, a Georgian organisation and an entrepreneur natural person shall submit to a tax authority,

according to the place of tax registration, information on opening bank accounts (other than deposit (time deposit)

accounts) outside Georgia within five business days after opening such accounts.

2 1 . A financial institution of Georgia defined in the Agreement between the Government of the United States of America

and the Government of Georgia to Improve International Tax Compliance and to Implement the Foreign Account Tax

Compliance Act (FATCA) shall, within the framework of this Agreement, transfer to a tax authority the information

provided for under the same Agreement.

3. A taxpayer shall submit to a tax authority the information set forth in the second paragraph of this article in the form

approved by the Minister of Finance of Georgia.

4. For non-fulfilment or improper fulfilment of the obligations provided for by the tax legislation of Georgia, a taxpayer

shall be liable as prescribed by this Code and/or other legislative acts of Georgia.

Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011

Law of Georgia No 5557 of 20 December 2011 – website, 28.12.2011

Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012

Law of Georgia No 4458 of 28 October 2015 – website, 11.11.2015

Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015

Law of Georgia No 5144 of 27 May 2016 – website, 4.6.2016

Article 44 – Correspondence with taxpayers

1. A tax authority shall send and/or present a document to a person in writing or electronically.

2. A document sent in writing by a tax authority shall be signed by an authorised person. The addressee shall be given the

original or a certified copy of the document.

2 1 . If upon the presentation of a written document to the address of persons defined under the sixth and seventh

paragraphs of this article or to the legal address defined in registration documents, the clerical office or the structural unit

of the same function refuses to accept a written document, the tax authority shall be entitled to use technical means for

recording the refusal.

3. A tax authority shall decide on the form of sending and/or presenting a document.

4. If the same document is presented to a person several times or in several forms, the date of presenting such document

shall be the day on which the document was first delivered.

5. If upon the presentation of a written document a person refuses to accept it, the presenting person shall make an

appropriate note.

5 1 . In the case provided for under the fifth paragraph of this article, if the fact of presenting a written document has been

recorded using technical means, such document shall be deemed accepted.

http://www.matsne.gov.ge 20000000005001016012

6. A written document shall be deemed to have been served on a natural person if the document is delivered to:

a) the addressee in person;

b) an authorised or legal representative of the person;

c) any adult family member residing with that person at his/her place of residence;

d) a clerical office or any structural unit of the same function at the place of business of an entrepreneur natural person;

e) a person directly performing the economic activity of a natural person, when there is an order of an authorised person

on execution of a tax offence report, current control procedures and/or tax enforcement measures.

7. A written document shall be deemed to have been served on a taxpayer (other than a natural person) if the document is

delivered to:

a) the authorised person;

b) an authorised or legal representative of the person;

c) a clerical office or any structural unit of the same function at the legal address indicated in registration documents;

d) a person directly performing the economic activity of a taxpayer, provided there is an order of an authorised person on

the execution of a tax offence report, current control procedures and/or tax enforcement measures;

e) any adult person residing at the residential apartment indicated as a legal address in registration documents.

8. The delivery of a document shall be confirmed by the recipient’s signature on a copy of the document or on the

relevant mail document. The recipient’s full name and his/her relationship with the addressee, as well as the date of

delivery of the document shall be indicated next to it.

9. A document sent electronically by a tax authority to a person shall be deemed delivered as soon as the addressee

reviews it, and in the case provided for in Article 264(2) of this Code – as soon as the person reviews it or on the 30 th day

after it has been posted on an authorised user’s page, unless the addressee reviewed the notice within that period.

10. A tax authority/a dispute resolution body or the National Bureau of Enforcement shall have the right to make a

document public if a taxpayer (except for a natural person) has not read the document sent by the tax authority in an

electronic form within 30 days after it is posted on the authorised user’s webpage of the taxpayer. If a taxpayer is a natural

person, a document can be made public if the following conditions have been met:

a) the document has been sent/submitted to a person at least twice in a written form but it could not be served on the

addressee;

b) the person is not an authorised user of the official webpage of the Revenue Service or the addressee has not read the

document within 30 days after it was posted on the authorised user’s webpage;

11. A document shall be published by posting it on the official website of the Ministry of Finance of Georgia or the

National Bureau of Enforcement and shall be deemed to have been delivered on the 20th day after such posting.

12. In exercising the rights defined in this Code, a tax authority may create, receive, send, keep and issue any electronic or

written document (including in archived form) that may have legal implications, and use an electronic document

circulation system.

13. A taxpayer may present documents to a tax authority in writing or electronically.

14. A written document presented by a taxpayer to a tax authority shall be signed by an authorised person. The original

document or its certified copy shall be submitted to the addressee.

15. If a taxpayer sends a document to a tax authority by post, the date of its submission shall be the day when the

document is sent. At the same time, the term for responding to the document shall commence from the day following the

day on which the mail is actually delivered to a tax authority.

16. The procedure for electronic correspondence/public dissemination of documents between a taxpayer and a tax/dispute

resolution authority shall be determined by an order of the Minister of Finance of Georgia.

Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011

Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011

Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011

Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013

Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015

Law of Georgia No 649 of 21 April 2017 – website, 10.5.2017

Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017

Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023

SECTION III

PROVIDING INFORMATION TO TAXPAYERS AND THE SYSTEM OF GEORGIAN TAX AUTHORITIES

Chapter V – Providing Information to Taxpayers

Article 45 – (Deleted)

Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013

Article 46 – Clarifications on the application of the tax legislation of Georgia

http://www.matsne.gov.ge 20000000005001016012

A tax authority may send a written clarification to a person on the application of the tax legislation of Georgia. This

clarification shall be regarded as a recommendation.

Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014

Article 46 1 – Public rulings

1. Based on a decision made by a dispute resolution authority or on the analysis of the current practice of taxation of

taxpayers by a tax authority, the Minister of Finance of Georgia may issue a public ruling on the application of certain

provisions of the tax legislation of Georgia.

2. A document shall be regarded as a public ruling if it states that it is a public ruling.

3. A public ruling (including a decision on modifying or cancelling a public ruling) shall be published on the official

website of the Legislative Herald of Georgia.

4. A public ruling shall enter into force from the date indicated in it and shall be valid for an indefinite term or for the

period stated in it. This ruling shall be binding for a tax authority from the day of its entry into force.

5. A public ruling shall not be applied if the provisions with respect to which the ruling was issued have been modified or

repealed.

6. The Minister of Finance may declare a public ruling, or its part, as invalid or modify it.

7. If a person acts according to a public ruling, a monitoring/law-enforcement authority may not adopt a decision

contradicting the ruling and may not impose additional taxes/sanctions.

8. If there is contradiction between two public rulings or between a public ruling and an advance tax ruling, the person

concerned may act according to one of the rulings at its discretion.

9. The procedure for issuing a public ruling shall be determined by the Minister of Finance of Georgia.

Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014

Article 47 – Advance tax ruling

1. The Revenue Service may, on the basis of a person’s application, issue an advance tax ruling according to a future or

completed transaction on:

a) the tax reporting rules provided for by this Code and Customs Code of Georgia and/or outstanding tax/customs

liabilities;

b) the reporting rules and/or outstanding liabilities related to a fee administration of which is carried out by a tax

authority.

2. An advance tax ruling shall be issued within not later than 90 days after submission of a request.

3. An advance tax ruling shall apply only to the persons to whom it has been issued. At the same time, an advance tax

ruling shall indicate the norm of the legislation of Georgia on which the ruling was based.

4. Different advance tax rulings may not be issued with respect to identical transactions performed by different persons.

5. If a person acts under an advance tax ruling, controlling/law-enforcement authorities may not make decisions

contradicting the advance tax ruling or impose any charges and/or sanctions.

6. An advance tax ruling shall not be applied if:

a) the facts and circumstances indicated in the advance tax ruling and which would have affected the advance tax ruling

are different from those actually existing;

b) the norm of the legislation of Georgia which formed the basis for the advance tax ruling has been repealed or amended.

7. A norm of the legislation of Georgia that is unfavourable to a taxpayer and has been given retroactive force may not

affect a transaction performed under an advance tax ruling issued prior to enactment of such norm.

8. (Deleted – 28.6.2019, No 4906).

9. The information provided by a person in a request for an advance tax ruling shall be treated as a tax secret.

10. If a person disagrees with an advance tax ruling of a tax authority, he/she may appeal it as provided in this Code.

11. An advance tax ruling shall need to be agreed upon with the Minister of Finance of Georgia.

12. At the request of a person and in the case of submission of additional or amended information, the Revenue Service

may amend its advance tax ruling, unless the person has already applied the advance tax ruling issued before such

amendment, in relation to the transaction on which the ruling was based.

13. The procedure for issuing an advance tax ruling shall be determined by order of the Minister of Finance of Georgia.

Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011

Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012

Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013

Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019

Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020

Chapter VI – Georgian Tax Authorities and their Main Functions

Article 48 – Georgian tax authorities

1. Georgian tax authorities shall be the Revenues Service and its structural units as determined by the Minister of Finance

http://www.matsne.gov.ge 20000000005001016012

of Georgia.

2. The Revenue Service is a legal entity under public law within the Ministry of Finance of Georgia exercising public

control. The Revenue Service exercises its powers across the whole territory of Georgia and may have offices in one or

several locations.

3. Georgian tax authorities shall exercise tax control in Georgia, except where such power is granted under this Code to

another authority.

Law of Georgia No 4705 of 20 May 2011 – website, 1.6.2011

Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011

Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015

Chapter VII – Rights and Obligations of Tax Authorities

Article 49 – Rights of tax authorities

1. Under this Code, within the scope of their authority and in the manner provided for by the legislation of Georgia, tax

authorities may:

a) audit financial documents, books, accounts, cost estimates, funds, securities and other valuables, computations,

declarations, and other tax computation and payment documents;

b) obtain from taxpayers and/or their representatives tax computation and payment documents, as well as written and

oral explanations regarding issues arising in the course of tax audit;

c) examine production, storage, sales and other facilities of enterprises, organisations and entrepreneur natural persons,

perform tax monitoring, take inventory of stock of goods, conduct observations by time-study or any other method and

determine the number of taxable objects, conduct tax audits, monitor taxpayer observance of the rules for use of cash

registers and, in the case of non-compliance with this rule, determine and impose appropriate liabilities under the

legislation of Georgia with respect to those persons;

d) summon taxpayers to a tax authority (a taxpayer’s legal or authorised representative who has accounting documents

and/or information related to the taxation of the taxpayer may appear before a tax authority instead of the taxpayer);

e) independently determine the amount of tax liabilities of a taxpayer based on information held by the tax authority

(including information on the expenditures of a taxpayer) or by a comparison method – by analysing information of other

similar taxpayers, unless a taxpayer submits the accounting documents required for tax control or performs bookkeeping

in violation of established procedure, or in other cases provided for by this Code;

f) apply sanctions against taxpayers who have violated the tax legislation of Georgia;

g) for the enforcement of payment of tax arrears, apply the measures provided for by this Code against a taxpayer;

h) prepare administrative offence reports against offenders for tax legislation violations and adopt rulings on the

imposition of administrative sanctions;

i) perform a test purchase of goods/services from a taxpayer to fully determine an object of taxation;

j) hire specialists or experts for tax administration purposes;

k) obtain data, certificates, documents and other necessary information free of charge from the state and municipality

bodies for work-related purposes. Where necessary, the procedure for exchange of information between state bodies shall

be determined by a resolution of the Government of Georgia;

l) request and obtain copies of accounting documents (a copy certified by the taxpayer, if necessary);

m) install readers and/or obtain their readings and seal documents and other materials in the manner provided for by this

Code.

n) receive from a financial institution of Georgia defined in the Agreement between the Government of the United States

of America and the Government of Georgia to Improve International Tax Compliance and to Implement the Foreign

Account Tax Compliance Act (FATCA), within the framework of this Agreement, the information provided for under the

same Agreement, and transfer this information to a competent body of the United States of America defined under the

Agreement.

2. Tax authorities shall also have the rights provided under this Code and other legislative acts.

3. Under an agreement between a tax authority and the National Bureau of Enforcement, in order to secure the payment

of tax arrears falling within the authority of a tax authority under the tax legislation of Georgia, the National Bureau of

Enforcement shall demand and obtain a list of assets from a taxpayer for the purpose of seizing a taxpayer’s property, take

inventory of a person’s property, evaluate the property, prepare an act for seizure of the property, seal the property,

ensure registration of a seizure of the taxpayer’s property with a registration authority, prepare a report on tax offences

where so prov