Georgia: New corporate income tax rules in 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 2026

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

Georgia: New corporate income tax rules in Georgia

pushkaryova.jpg

Anna Pushkaryova

Georgia has introduced amendments to the corporate income tax (CIT) into the Tax Code through Law N5092-II, dated May 13 2016.

Most of amendments entered into force on June 1 2016. These include:

  • extending the term of import VAT payment on certain types of fixed assets up to 45 days as of the date of realisation of such assets;

  • exclusive power of tax authorities to exercise tax control over the company`s economic activities and, accordingly, carry out tax audits;

  • writing off the tax arrears of taxpayers, who do not carry out economic activities with respect to tax liabilities arisen and sanctions imposed up to a certain deadline;

  • the prohibition to freeze a taxpayer`s bank account during a tax dispute, except when the issue is based on a court ruling.

The law also introduces certain amendments relating to the removal of thin capitalization rules and introduction of CIT on distributed profits, which will enter into force on January 1 2017.

Based on the new rules, the rate of CIT remains unchanged. Additionally, the law includes a list of profits and activities that are subject to CIT, including (but not limited to):

  • Free of charge supply of goods and services;

  • Loan issuance to an individual or a non-resident;

  • Certain non-deductible expenses according to the Georgian tax legislation; and

  • Distributed profit to related parties or a person who is exempt from taxation, as well as transactions not conducted based on an arms-length principle.

Certain banking and non-banking financial institutions are exempt from the new CIT rules until January 1 2019.

Finally, the transition provisions of the law contain some specific rules regarding the profit distribution by a Georgian legal entity earned before the amendments entered into force.

Anna Pushkaryova (anna.pushkaryova@eurofast.eu)

Eurofast Georgia

Tel: +995 595 100 517

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes
While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions
While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard
Moore, founding partner of the Chicago tax boutique which bears her name, shares her career wisdom for ITR’s new Women in Tax interview series
But partners at the firm admit that jumping ship to the US would not be as easy as some believe
Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created
Wingrove will succeed Bill Thomas, who has served in the role since 2017; in other news, Andersen unveiled a sharp increase in revenues for 2025
Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management
While all options presented ‘drawbacks’, European Commission tax leader Wopke Hoekstra said the controversial US carve-out deal has ‘many benefits’
Gift this article