2026-10-08 · Tax & Residency
Georgia's 15 percent company tax is charged when profit leaves, not when it is earned — and several things count as leaving
Reinvested profit is untaxed, which is the headline every adviser repeats. The part worth knowing is the list of outflows that trigger the charge anyway.
How the deferral works, and how the rate is applied
Since 2017 Georgia has taxed company profit at the point it leaves the business rather than when it is earned. Retained earnings that stay in the company are not taxed, which is the design intent: reinvestment is cheaper than distribution. The rate is 15 percent, but it is applied to a grossed-up base — the outflow is divided by 0.85 before the rate is applied. The worked example from Andersen's summary: a dividend of 85,000 lari produces a tax liability of 15,000 lari. Budget from the gross figure, not from 15 percent of the payment you intend to make.
What counts as a distribution even when it is not one
The summary lists several outflows that attract the charge. Dividends in cash or in kind, plainly. Related-party transactions on terms that depart from market terms, and transfer pricing adjustments, can create a deemed distribution. Expenses not connected to economic activity are caught, including undocumented expenses, payments and loans to entities in preferential tax jurisdictions, and interest above the rates set by the Ministry of Finance. Free transfers of goods, services or funds are caught, with exceptions for certain capped charitable donations, transfers to government bodies and gratuitous supplies to other profit-tax payers. Representative expenses above one percent of the prior year's revenues or expenses, whichever is higher, are also treated as a distribution.
Exemptions, credits and who is outside the regime
Dividends paid between Georgian entities are exempt, as are dividends received from foreign subsidiaries unless the subsidiary sits in a preferential tax jurisdiction. Liquidation proceeds are excluded up to the shareholder's capital contribution. Where a loan to an entity in a preferential jurisdiction is later repaid, the tax paid on it can be credited back. Banks, credit unions, microfinance organisations, other lending entities, and gambling and gaming businesses do not use this regime at all; they follow a separate corporate tax treatment. If you are structuring a Georgian holding company on the assumption the deferral applies, confirm your activity is not on that excluded list.
Why this matters to a property owner
If you hold Georgian property through a company — common for developers and for owners of several units — the regime shapes when you take money out rather than how much you make. Rental income accumulating inside the company is untaxed at corporate level until distributed, which favours reinvesting into the next unit. The traps are mundane: paying a personal expense from the company account, an undocumented cash payment to a contractor, a loan to a related offshore entity, or hospitality spending above the one percent ceiling. Andersen's page reflects the law as of February 2026; verify the current position with the Revenue Service or a Georgian tax adviser before acting, as this is general information and not tax advice.
Source: Andersen in Georgia — Georgian Corporate Income Tax Regime · Also see: Revenue Service of Georgia, Legislative Herald of Georgia (matsne.gov.ge)
#company tax #structure #developers #compliance
Written by us from the source linked above, not investment, legal or tax advice. Figures and rules change — confirm anything that matters before acting on it.
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