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

HMRC expects advisers to meet ever-higher compliance criteria. After 24 consecutive qualified audit opinions, many will ask whether HMRC should hold itself to the same standards
The purchase of Marosa represents the second major tax tech consolidation this week, raising questions of a broader industry trend
Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments
Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test
The deals for TP Accurate and Intra Pricing Solutions will enhance Alphatax’s ability to support clients with the full TP lifecycle, the tax tech provider claimed
The DS Advocates partner discusses career reinvention, tax disputes and why advisory and litigation experience should complement one another
Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings
Shared transaction semantics, governed data and reusable ERP design may prove the most significant benefits of the UK's move to Peppol
As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues
Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour
Gift this article