Georgia taxes on a territorial basis: Article 82 of the Tax Code exempts the foreign-source income of individuals, residents included, so that only their Georgian-source income is taxed. This is the key to understanding everything else, and the reason the country attracts freelancers paid from abroad.
Tax residence is acquired after 183 days3 of presence over a twelve-month period. Personal income tax is proportional, at a rate of 20%4, and dividends bear a rate of 5%5.
A second route to tax residence exists for wealthy individuals who do not meet the presence condition: the "high-net-worth" tax resident status, provided for by Article 34 of the Tax Code and an order of the Minister of Finance of 1 March 2023. It requires high worldwide assets or annual income, assets located in Georgia and a local link (residence permit, nationality or Georgian-source income), and is confirmed each year. It grants residence and the corresponding certificate, without any additional exemption. We do not give figures for the thresholds: to date they appear only in private professional sources, not in the official text.
The small business status
This is the scheme on which the country's tax reputation rests. A sole proprietor registered under this status is taxed not on profit but on turnover, at a rate of 1%6, up to an annual ceiling of up to GEL 500,0007.
Above this ceiling, the rate rises to 3%8. The approximate equivalent value of the ceiling is about about €170,0009: this order of magnitude allows a well-paid freelancer to remain in the regime for several years.
The status is neither automatic nor universal: it requires registration, and certain activities are excluded. A regulated profession or a consulting activity of a particular nature may not qualify, and this should be checked before settling, not afterwards.
Companies
Georgian corporate tax is based on a so-called Estonian model: undistributed profit is not taxed, at a rate of 0%10, with taxation arising on distribution, at a rate of 15%11.
This model mechanically favours reinvestment. It also changes the nature of the trade-off for a manager: the question is not how much he or she will pay on profit, but when he or she will choose to take it out.
One point deserves emphasis for a French freelancer: Georgian territoriality and the small business status combine poorly with clients who remain in France. If services are provided from Georgia to French clients, the question of the source of the income and that of a possible permanent establishment arise on both sides. The headline rate says nothing about this analysis, which is the real difficulty of the case.