News brief · Taxation
Georgia: HNWI tax residency without 183 days
Georgia allows tax residency to be acquired without spending half the year there, based on a wealth and income criterion. It is an exceptional rule, and it runs into the same limits as its equivalents.
By Editorial team · on March 19, 2026
The two Georgian routes
The ordinary route is based on presence: Georgian tax residency is acquired above 183 days1 of annual presence.
An alternative route exists for high-net-worth individuals, based on a wealth and income criterion rather than on length of stay.
We do not publish the wealth threshold, the income threshold or the documents required for this route: they do not appear in the official sources we were able to verify. They must be established with the Georgian tax administration.
What can be said is that this type of rule is not unique to Georgia. Cyprus has a comparable rule, allowing tax residency with from 60 days2 of presence, subject to four cumulative conditions.
These schemes target the same profile: a highly mobile person with no tax residency elsewhere, who would otherwise not reach the threshold in any State.
Three notions that everyday language confuses, in Georgia as elsewhere, must be distinguished: the right to enter without a visa, the residence permit, and tax residency. All three are obtained separately, fall under different authorities, and none can be inferred from the others.
A French national may thus stay a whole year without a visa, without holding a residence permit, and without being a Georgian tax resident — or be one, if they have crossed the presence threshold. The distinction is established by documents, not by intuition.
The limit common to these rules
Tax residency acquired with very limited presence is fragile when faced with another State claiming the same person.
In France, Article 4 B of the French General Tax Code (code général des impôts) sets out four alternative criteria: the household, the place of principal stay, professional activity and the centre of economic interests. Just one is enough to keep tax domicile.
In the event of dual residence, the applicable treaty breaks the tie according to a hierarchical sequence: permanent home, centre of vital interests, habitual abode, nationality.
A home kept in France and available all year round weighs from the very first criterion. A minimal Georgian presence, combined with a family that has remained in France, does not withstand this scrutiny.
These rules are therefore only of interest to someone who genuinely has no ties anywhere else. They are not a shortcut; they are an answer to a situation of tax statelessness.
What else Georgia offers
The country applies de facto territoriality to several categories of income, and its ordinary rules tax personal income at 20%3 and dividends at 5%4.
The small business status taxes turnover at 1%5 under an annual ceiling of up to GEL 500,0006, or around about €170,0007, then at 3%8 above it.
For companies, the country applies tax deferral comparable to the Estonian model: 0%9 on undistributed profits, 15%10 on distributed profits.
Finally, nationals of many countries, including France, can stay for 365 days11 without a visa — a period with no equivalent, which nonetheless amounts neither to a residence permit nor to tax residency.
Key takeaways
- The reduced-presence route exists, but its conditions are not documented in our verified sources.
- It only protects someone who is not a tax resident anywhere else.
- The Georgian certificate of tax residency is needed to invoke a treaty.
- The small business status and tax deferral are the country's real assets.
- The 365 days11 visa-free stay moves neither residence nor tax residency.
Finally, the political and regional context is a factor in its own right. Georgia has experienced sustained internal tensions, and its geographical position, on the doorstep of Russia and the Caucasus, is a risk parameter that tax comparisons ignore — and which, for a wealthy household, matters more than a percentage point of tax.
Please note
Sources and verification dates
- 1.
Georgia: annual presence above which tax residency is acquired : 183 days
« 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. »
matsne.gov.geVerified on Nov 2, 2026Verified source
- 2.
Cyprus: minimum annual presence under the so-called sixty-day rule : 60 days
« 60-day rule — An individual may be considered a tax resident of Cyprus even if they have not completed 183 days in Cyprus, provided that they meet all of the following conditions: They remain in Cyprus for at least 60 days during the tax year. They do not reside for more than 183 days during the year in another country. They carry on any business in Cyprus and/or are employed in Cyprus, whether as an employee and/or office holder. They maintain a permanent residence in Cyprus which they own or rent. — Tax Department, « Tax Residency/Domicility » (Income Tax Law N. 118(I)/2002, art. 2). »
gov.cyVerified on Nov 2, 2026Verified source
- 3.
Georgia: personal income tax rate : 20%
« A natural person's taxable income shall be taxed at the rate of 20%, unless otherwise provided for by this Code. »
matsne.gov.geVerified on Nov 2, 2026Verified source
- 4.
Georgia: tax rate on dividends : 5%
« Article 130 - Taxation of dividends at the source — 1. Dividends paid by a resident enterprise to a natural person, a non-entrepreneurial (non-commercial) legal entity or a non-resident enterprise shall be taxed at source at the rate of 5% of the amount payable, unless otherwise provided for by this article. — Tax Code of Georgia, art. 130. »
matsne.gov.geVerified on Nov 2, 2026Verified source
- 5.
Georgia: tax rate on turnover under small business status : 1%
« Taxable income of a person having the status of a small business shall be taxed at 1%, except as provided for paragraph 2 of this article. »
matsne.gov.geVerified on Nov 2, 2026Verified source
- 6.
Georgia: annual turnover cap for small business status : GEL 500,000
« the GEL 500 000-limit of the gross income received during a calendar year determined for a natural person having the status of a small business »
matsne.gov.geVerified on Nov 2, 2026Verified source
- 7.
Georgia: approximate euro equivalent of the turnover cap for small business status : €170,000
« Article 90 — 2. […] 3% if his/her gross income received from the economic activities of this person has exceeded GEL 500 000 — Tax Code of Georgia, art. 90. Seuil légal en laris (500 000 GEL ≈ 160 000–170 000 € au cours 2026). »
matsne.gov.geVerified on Nov 2, 2026Verified source
- 8.
Georgia: rate applicable to turnover above the small business status cap : 3%
« Taxable income of a person having the status of a small business shall be taxed at 3% if his/her gross income received from the economic activities of this person has exceeded GEL 500 000, and in the case of wine tourism operators and agro tourism operators if the said gross income has exceeded GEL 700 000. »
matsne.gov.geVerified on Nov 2, 2026Verified source
- 9.
Georgia: taxation of companies’ undistributed profits : 0%
« Article 97 - Object of profit taxation — 1. The object of profit taxation of a resident enterprise […] shall be: a) the distributed profit; b) the expenses borne or other payments not related to the economic activity […] — Tax Code of Georgia, art. 97 (modèle estonien : les bénéfices non distribués ne sont pas imposés). »
matsne.gov.geVerified on Nov 2, 2026Verified source
- 10.
Georgia: rate applicable to distributed profits : 15%
« Article 98 – Tax rate 1. The profit tax rate shall be 15%, except as provided for by paragraphs 2, 4, 5 and 6 of this article. »
matsne.gov.geVerified on Nov 2, 2026Verified source
- 11.
Georgia: length of visa-free stay for nationals of listed countries : 365 days
« Citizens of the countries listed in the annex may enter and stay in Georgia without visa for one full year. »
matsne.gov.geVerified on Nov 2, 2026Verified source