International Tax Review is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

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

Georgia: New corporate income tax rules in Georgia


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 (

Eurofast Georgia

Tel: +995 595 100 517


more across site & bottom lb ros

More from across our site

COVID-19 and an overworked HMRC may have created the ‘perfect storm’ for reduced prosecutions, according to tax professionals.
Participants in the consultation on the UN secretary-general’s report into international tax cooperation are divided – some believe UN-led structures are the way forward, while others want to improve existing ones. Ralph Cunningham reports.
The German government unveils plans to implement pillar two, while EY is reportedly still divided over ‘Project Everest’.
With the M&A market booming, ITR has partnered with correspondents from firms around the globe to provide a guide to the deal structures being employed and tax authorities' responses.
Xing Hu, partner at Hui Ye Law Firm in Shanghai, looks at the implications of the US Uyghur Forced Labor Protection Act for TP comparability analysis of China.
Karl Berlin talks to Josh White about meeting the Fair Tax standard, the changing burden of country-by-country reporting, and how windfall taxes may hit renewable energy.
Sandy Markwick, head of the Tax Director Network (TDN) at Winmark, looks at the challenges of global mobility for tax management.
Taxpayers should look beyond the headline criteria of the simplification regime to ensure that their arrangements meet the arm’s-length standard, say Alejandro Ces and Mark Seddon of the EY New Zealand transfer pricing team.
In a recent webinar hosted by law firms Greenberg Traurig and Clayton Utz, officials at the IRS and ATO outlined their visions for 2023.
The Asia-Pacific awards research cycle has now begun – don’t miss on this opportunity be recognised in 2023