Why Country Georgia for Business?
Country Georgia offers numerous advantages for business registration and operation, significantly influenced by its favorable Tax Law framework, including:
Low overall tax rates
Tax incentives for individuals and companies
Special tax regimes for targeted industries
Simplified corporate tax system (0% on reinvested profit)
Ease of doing business and cost-efficiency
Transfer Pricing (TP) Services in Country Georgia
Understanding and complying with transfer pricing regulations is a critical aspect of international Tax Law. We provide a full suite of Transfer Pricing (TP) services to ensure compliance with Country Georgian Tax Law and OECD Guidelines, including:
- Preparing TP documentation in line with Country Georgian legislation and OECD standards.
- Setting up TP policy and providing ongoing consultation for intra-group transactions, ensuring alignment with current tax law requirements.
Transfer Pricing Law in Country Georgia
Country Georgia’s Transfer Pricing regime has been in effect since 2013, following the issuance of Decree #423 by the Ministry of Finance. This decree aligns previously unregulated matters with the OECD Transfer Pricing Guidelines (2017). Key components influencing TP under local Tax Law include:- Tax Code Articles 126–129 (1): Active since 2011, fully enforced post-Decree #423.
- Internal guidelines by the Country Georgian Revenue Service (GRS): Explain practical issues like interquartile range calculations.
- Special TP division established within the GRS in 2015 — our founder led this team from its inception, providing deep insight into the application of tax law in practice.
TP Documentation Requirements
- Annual Obligation: TP documentation must be prepared yearly unless a low-turnover exemption applies (renewable every three years).
- Submission Deadline: TP documentation must be submitted within 30 days upon request by tax authorities.
- Penalties for Non-compliance:
- Initial fine of GEL 400.
- Increased penalties for repeated violations.
- Failure to prepare documentation shifts the burden of proof to the taxpayer, increasing exposure to additional taxes, interest, and penalties under tax law.
Permanent Establishment (PE) Services in Country Georgia
We offer comprehensive Permanent Establishment (PE) support to help foreign companies comply with Country Georgian tax regulations and OECD standards, especially regarding Transfer Pricing-based profit attribution, a complex area of international Tax Law.
Our PE Services Include:
- Tax registration for “Small Business” status (1% tax rate);
- Registration as a “Virtual Zone Person” (0% Corporate Income Tax, subject to conditions for IT companies);
- Registration as an “International Company” (5% Corporate Income Tax, 5% tax on salaries, 0% tax on dividends, 0% property tax, considering conditions for IT and shipping/logistics companies);
- Preparation of Transfer Pricing (TP) documentation in compliance with Georgian legislation and OECD Guidelines;
- Establishment of TP policy and offering ongoing consultation for intra-group transactions; (As mentioned before, “Preparation of Transfer Pricing documentation” is listed twice. If it implies a different aspect or a follow-up service, it might need clarification. Otherwise, it’s a repetition. For now, I’ll translate it as it is, assuming it might be a specific focus.) Preparation of Transfer Pricing documentation;
- Permanent Establishment (PE) services in Georgia.
We offer comprehensive Permanent Establishment (PE) services to ensure compliance with Georgian tax legislation and OECD Guidelines, including support for profit attribution based on Transfer Pricing (TP) rules.
Assessment of whether your activities trigger a PE under Georgian tax legislation and OECD rules.
Identification of risks and obligations associated with the establishment of a PE.
In parallel with legal support, our team offers businesses full tax and audit services, consultations on tax-related matters, assistance with business redomiciliation to Georgia (transferring your business without interrupting operational processes), and implementation of proper tax administration to significantly reduce costs.
