Published by Bookkeeping.ge — Assio Lex and Associates LLC
Updated
International tax and business in Georgia
A double taxation treaty can reduce tax on a cross-border payment, determine where business profits are taxed or help resolve overlapping tax claims. Bookkeeping.ge helps companies and individuals apply Georgia’s treaty rules to actual income, supported by the right certificates and accounting records.
Discuss your international tax question
What a double taxation agreement does
A double taxation agreement, often called a DTA or tax treaty, allocates taxing rights between two jurisdictions. The result depends on the person receiving the income, the type of income and the relevant treaty article. Residence, business profits, employment, dividends, interest, royalties and property income are different parts of the analysis.
Begin with the domestic tax position, then consider treaty relief. A treaty ceiling does not increase a lower domestic rate. Where relief is available, the payment records and procedural filings should explain why the reduced rate or exemption was used.
Georgia’s double taxation treaty network
As reviewed on 18 October 2026, Georgia has 58 double taxation treaties in force. The network includes the following treaty partners. Country coverage alone does not determine the result: the applicable text, effective dates and any relevant Multilateral Instrument changes must be matched to the payment.
| Partners A–G | Partners H–P | Partners Q–U |
|---|---|---|
| Armenia | Hong Kong | Qatar |
| Austria | Hungary | Romania |
| Azerbaijan | Iceland | San Marino |
| Bahrain | India | Saudi Arabia |
| Belarus | Iran | Serbia |
| Belgium | Ireland | Singapore |
| Bulgaria | Israel | Slovakia |
| China | Italy | Slovenia |
| Croatia | Japan | South Korea |
| Cyprus | Kazakhstan | Spain |
| Czech Republic | Kuwait | Sweden |
| Denmark | Kyrgyzstan | Switzerland |
| Egypt | Latvia | Turkey |
| Estonia | Liechtenstein | Turkmenistan |
| Finland | Lithuania | Ukraine |
| France | Luxembourg | United Arab Emirates |
| Germany | Malta | United Kingdom |
| Greece | Moldova | Uzbekistan |
| Netherlands | ||
| Norway | ||
| Poland | ||
| Portugal |
The United States is not included in this list. A business should establish that a treaty is in force with the relevant jurisdiction before relying on treaty benefits. A foreign bank account or a company registration certificate is not a substitute for this check.
Match the treaty article to your income
| Income | Key question | Prepare for the review |
|---|---|---|
| Business services | Which business-profits or services provision applies, and is there a Georgian permanent establishment? | Contract, service description, work locations and presence in Georgia |
| Dividends | Does the recipient meet the residence, ownership and beneficial-ownership conditions? | Share register, ownership history and residence certificate |
| Interest | Who receives the financing return and what treaty conditions apply? | Loan agreement, lender details and payment schedule |
| Royalties and software rights | What rights are supplied, and how does the treaty classify them? | Licence terms and a description of the rights used |
| Employment | Where is work performed, who is the employer and who bears the cost? | Travel record, employment agreement and recharge arrangements |
| Property income | Where is the property located and which treaty provision covers the income or gain? | Ownership documents, lease or sale agreement |
For employment income, a reference to “183 days” is not a complete treaty analysis. The employer and the entity bearing the remuneration can also determine the result. For a business, the permanent establishment review should be completed alongside the treaty assessment.
Residence certificates, relief and refunds
Georgia’s treaty-relief procedure is governed by Minister of Finance Order No. 633 of 28 December 2011. It provides routes for relief at source and repayment of excess tax, supported by a residence certificate from the competent foreign authority and the required Georgian translation.
Form N1 is the tax agent’s information return for treaty exemption or reduced withholding, generally due by 1 April following the reporting year. Form N2 is the non-resident’s declaration and refund claim. Collect the contract, payment details and certificate for the relevant period before preparing either route.
A practical payment file should let the accountant follow the transaction from the agreement through the invoice, bank payment, tax calculation and declaration. For a refund, add evidence of the tax already withheld and reconcile the claim to the original payment.
Beneficial ownership and treaty anti-abuse rules
Treaty relief requires more than selecting the country with an attractive headline rate. Examine the recipient’s role, the commercial arrangement and any onward payment. Beneficial-ownership requirements and treaty anti-abuse provisions can affect whether the benefit is available.
The Multilateral Instrument can modify covered treaties. A review should use the applicable treaty position for the relevant period, including changes that affect entitlement to benefits. An old country-rate spreadsheet can be a useful prompt, but it cannot explain all ownership, holding-period and anti-abuse conditions.
When two countries tax the same income
First identify what has actually been taxed: the recipient, income, period and legal basis in each country. Keep assessment notices and proof of payment. The treaty may provide a credit or exemption mechanism, while a correction or refund may be needed where a payment was treated incorrectly.
A Mutual Agreement Procedure, or MAP, can address taxation inconsistent with a treaty. It is a separate route from a domestic appeal. A business facing an assessment should track both procedures and their time limits rather than assuming that one protects the other.
Double taxation treaty support for your business
Our accounting and tax team can review cross-border income, organise residence-certificate requirements, prepare withholding calculations and support treaty-relief and refund documentation. Tax advisors and tax lawyers within Assio Lex and Associates LLC can connect the accounting work with the wider international tax question.
Tell us the two countries involved, the type of payment, whether payment has already taken place and any tax withheld. For a recurring arrangement, we can help establish a payment checklist your finance team can reuse. Explore withholding tax on payments abroad and tax residency and foreign income for the next steps.
Double taxation treaty questions
Does a treaty make every foreign payment tax free?
No. Each income category has its own rules, and relief depends on the recipient and supporting documents. VAT is a separate review from the income-tax treaty.
Can relief be considered after tax has been withheld?
Yes. Review the refund route, the evidence of withholding and the relevant time limits. Start with the original payment records so the claim can be reconciled.
Can you coordinate the Georgian side with our overseas accountant?
Yes. We can organise the Georgian calculations and records and work with your overseas advisor on the information each country needs.