Georgia: Kyrgyzstan ratifies double tax treaty with Georgia

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Georgia: Kyrgyzstan ratifies double tax treaty with Georgia

intl-updates-small.jpg
lopatina.JPG

Irina Lopatina

On June 22 2017, the parliament of Kyrgyzstan approved the bill ratifying the tax treaty signed with Georgia on October 13 2016. Currently, the ratification from the Georgian side is still pending, and in order to become law and to be ratified, the bill still needs to be signed by the presidents.

The 2016-signed treaty covers taxes on income and profit taxes. In the case of Georgia, these would be the profit tax and income tax, while in Kyrgyzstan the income tax on individuals and tax on income and profits of legal persons. The agreement will also be applicable to similar taxes that may be imposed at a later stage, on the condition that the signatory parties notify each other about the tax changes introduced.

Permanent establishments (PEs) are deemed to arise when a building, construction site or an installation project or related supervisory activity lasts for more than six months. Additionally, a PE also includes a place of management, a branch, an office, a factory, a workshop or a mine or oil/gas well.

In terms of withholding tax rates, dividends are to be taxed at 5% of the gross amount of the dividends if the beneficial owner holds at least 25% of the capital of the company paying the dividends and 10% of the gross amount of the dividends in all other cases. The withholding tax rate for interest has been set at 5%, while for royalties at 10%.

Once the double tax agreement enters into force its provisions shall have effect in respect of taxes withheld at source on or after the first day of January of the year following the one during which the agreement enters into force.

Irina Lopatina (irina.lopatina@eurofast.eu), Tbilisi

Eurofast Global

Tel: +995 322180310

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
Awards
The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club
The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles
Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure
If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests
If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues
As World Tax unveils its much-anticipated rankings for 2026, we focus on EMEA’s top performers in the first of three regional analyses
Firms are spending serious money to expand their tax advisory practices internationally – this proves that the tax practice is no mere sideshow
The controversial deal would ‘preserve the gains achieved under pillar two’, the OECD said; in other news, HMRC outlined its approach to dealing with ‘harmful’ tax advisers
Former EY and Deloitte tax specialists will staff the new operation, which provides the firm with new offices in Tokyo and Osaka
Gift this article