All material subject to strictly enforced copyright laws. © 2022 ITR is part of the Euromoney Institutional Investor PLC group.

New income tax treaty between Georgia and Moldova


A tax treaty between Georgia and Moldova is the first of its kind concluded between the two countries, and will enter into force after the ratification instruments are exchanged.

The treaty was signed following the Georgia-Moldova Business Forum held in Tbilisi, in April 2017, where participants explored business opportunities between the two countries in the agriculture, consulting, textile, information technology, tourism and development sectors, among others.

The parties signed a convention on the avoidance of double taxation and prevention of tax evasion in regards to income tax, in order to support the development of cooperation between the business communities of the two countries.

The treaty covers Georgian profit tax and income tax, as well as Moldovan income tax. In terms of withholding tax rates, the maximum rate of 5% was established on dividends, interest and royalties. Anti-treaty shopping provisions have been implemented in those articles as well.

A permanent establishment is deemed to include a building site or construction/installation project with a duration of more than six months within a 12-month period. The same applies to the provision of services (including consultancy) lasting more than three months in a 12-month period.

Both countries will apply the credit method and the exemption-with-progression method for the elimination of double taxation.


Irina Lopatina (, Tbilisi

Eurofast Global

Tel: +995 322180310


more across site & bottom lb ros

More from across our site

Speakers at ITR’s Global TP Forum Europe said TP analyses are often tied to the value created from a company’s ESG commitments.
Discussions around recharacterisation are better to avoid, as tax authorities could dismiss an entire TP transaction, said panellists at ITR’s Global TP Forum.
Several tax chiefs shared their administrations’ latest digital identity tracking systems and other tax technologies at the OECD’s annual meeting of authorities.
Businesses welcome the UK’s decision to scrap the IR35 reforms but are not happy about the time and money they have wasted to date.
Energy ministers agreed on regulations including a windfall tax on fossil fuel companies to address high gas prices at an extraordinary Council meeting on September 30.
The European Parliament raises concerns over unanimity in voting on pillar two, while protests break out over tax reform in Colombia.
Ramesh Khaitan speaks to reporter Siqalane Taho about tax morality, transfer pricing regulations, Indian tax developments, and the OECD’s two-pillar solution.
Join ITR and KPMG China at 10am BST on October 19 as they discuss the personal, employment, and corporate tax-related implications of employees working from overseas.
Tricentis and Boehringer Ingelheim, along with a European Commission TP specialist, criticised the complexity of pillar one rules and their scope at an ITR event.
Speakers at ITR’s Managing Tax Disputes Summit said taxpayers can still face lengthy TP audits, despite strong documentation preparation
We use cookies to provide a personalized site experience.
By continuing to use & browse the site you agree to our Privacy Policy.
I agree