Belarus
Georgia
Belarusian founders choose Georgia for the same reasons as their Russian neighbours: a short flight, a visa-free stay, a familiar language in business, and a one-day registration. The tax picture, however, is very different. Belarus has a tax treaty with Georgia, and it has no rules on controlled foreign companies.
This guide covers the treaty, how Belarus taxes the owner, how to move the capital under the currency rules, and what Georgian banks check.
What Georgia asks of a Belarusian founder
- One shareholder and one director, both of whom can be Belarusian.
- No minimum capital for a limited liability company.
- An apostilled power of attorney, with a Georgian translation: both countries apply the Apostille Convention.
- A legal address in Georgia.
- A visa-free stay for Belarusian citizens; working in Georgia has its own rules since 2026, explained in the non-resident guide.
The steps are in how to register a company in Georgia.
The tax treaty, in force since 2015
| Income from Georgia to Belarus | Treaty | Georgian domestic rate | What applies |
|---|---|---|---|
| Dividends | 5% or 10% | 5% | 5% at most |
| Interest | 5% | 5% | 5% |
| Royalties | 5% | 5% | 5% |
| Permanent establishment period listed | 12 months |
The treaty does not lower Georgian withholding below Georgia's own rates. Its value lies elsewhere: residence tie-breakers, permanent establishment rules, and a framework for the credit in Belarus.
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Belarus has no CFC rules
The Belarus Tax Code, in its version including the amendments of 30 December 2025, contains no regime that taxes a resident on the undistributed profit of a foreign company. That changes the meaning of Georgia's distribution model:
- Profit kept in the Georgian company is taxed neither in Georgia nor in Belarus.
- Tax arises when the dividend reaches the owner, in both countries.
- The stake must still be reported: a participation in a foreign organisation is notified to the tax office within ten working days (Article 22).
This is the opposite of the Russian position, where controlled foreign company rules reach undistributed profit; see the guide for founders from Russia.
How the dividend is taxed
| Step, per 100 of Georgian profit | Individual owner | Belarusian company as owner |
|---|---|---|
| Georgian distribution tax, 15% of the grossed-up base | 15.00 | 15.00 |
| Dividend paid | 85.00 | 85.00 |
| Georgian withholding at 5% | 4.25 | 4.25 |
| Belarusian tax before credit | 11.05 at 13% | 10.20 at 12% |
| Credit for Georgian withholding | 4.25 | 4.25 |
| Belarusian tax to pay | 6.80 | 5.95 |
| Left after all tax | 73.95 | 74.80 |
The rules behind the table:
- Residence (Article 17): more than 183 days in Belarus in the calendar year makes an individual resident, taxed on foreign income.
- Rate (Article 214): 13% on dividends, 25% above BYN 350,000 in the tax period.
- Declaration (Articles 219 and 222): foreign income is declared by 31 March of the following year.
- Credit (Article 224): foreign tax is credited, except on income from the presidential list of offshore zones. Georgia is not on that list as far as we know; check the current list.
- Company owner (Article 184): a Belarusian organisation pays 12% on dividends received.
Moving the capital out of Belarus
Law No. 226-Z replaced National Bank permits for capital operations with a registration system in 2021.
- Accounts abroad (Article 17): a resident may open accounts in foreign banks freely and move its own funds between them.
- Registration (Article 8): currency contracts are registered as the National Bank sets.
- Thresholds (Instruction No. 37): 2,000 base units for an individual, 4,000 for a legal entity or sole trader, or any contract with no fixed amount.
- A capital contribution is on the list: paying into the charter capital of a company created abroad, and later contributions.
- Timing: registration comes before the first transfer.
- The bank's veto (Article 22): a Belarusian bank may refuse an operation under an unregistered contract.
- 1Register the Georgian LLCCharter fixes the contribution
- 2Register the currency contractAbove 2,000 or 4,000 base units
- 3Transfer the contributionThrough your Belarusian bank
- 4Notify the tax officeWithin ten working days of becoming a participant
Georgian banks and Belarusian founders
On 26 February 2022, the National Bank of Georgia instructed the financial sector to comply with US, UK and EU sanctions against Russia and Belarus. In practice:
- Expect extended checks on Belarusian counterparties, banks and payment routes.
- Transfers from sanctioned Belarusian banks may be refused or delayed.
- A clean source-of-funds file matters more than the passport.
The process is set out in the business bank account guide.
The bottom line
For a Belarusian founder, Georgia works well on paper: a treaty in force, no Belarusian CFC rules, so profit kept in the Georgian company is not taxed in either country until it is paid out. On distribution, about three quarters of the profit remains. The practical hurdles are the currency contract registration before funding, and Georgian banks' sanctions screening.
corpsec registers the Georgian company and provides its registered office. See the Georgia formation service, or read what Georgian banks will ask for.
Frequently asked questions
Can a Belarusian citizen open a company in Georgia?
Yes. Georgia allows a single foreign shareholder and director with no minimum capital, and documents can be apostilled since both countries apply the convention.
Is there a tax treaty between Belarus and Georgia?
Yes. It is in force since 24 November 2015. Georgia lists 5% or 10% on dividends and 5% on interest and royalties.
Does Belarus have CFC rules?
No. The Belarus Tax Code has no regime taxing undistributed profit of a foreign company. A Belarusian resident is taxed when dividends are received, and must notify the stake within ten working days.
How much tax does a Belarusian pay on a Georgian dividend?
13% in Belarus, 25% above BYN 350,000, with a credit for the 5% Georgian withholding. On 100 of Georgian profit, an individual keeps about 74 after both countries' taxes.
Do I need permission to send capital from Belarus to Georgia?
Not a permit, but a currency contract registration above 2,000 base units for an individual or 4,000 for a company, before the first transfer.
Sources
- Ministry of Finance of Georgia, treaty table: Belarus, in force 24 November 2015, permanent establishment after 12 months, dividends 5% or 10%, interest 5%, royalties 5%
- Tax Code of Belarus, Special Part, consolidated text: Articles 184, 214, 219, 222 and 224 on dividend rates, the 31 March declaration and the foreign tax credit, and no chapter on controlled foreign companies
- Belarus Law No. 226-Z on currency regulation and currency control: free opening of accounts abroad (Article 17), registration of currency contracts (Article 8), the bank's right to refuse an unregistered operation (Article 22)
- National Bank of Belarus, Instruction No. 37 of 12 February 2021 on registration of currency contracts, consolidated with the 2022 and 2024 amendments: thresholds of 2,000 and 4,000 base units, capital contributions to a foreign company listed
- First Channel (1tv.ge): the National Bank of Georgia instructed the financial sector on 26 February 2022 to comply with US, UK and EU sanctions against Russia and Belarus
Official, read on 5 October 2026 for this series: the Belarus Tax Code in its consolidated version including the amendments of 30 December 2025, Law No. 226-Z, and National Bank Instruction No. 37 in its consolidated text. Official, read on 26 October 2026: the Georgian treaty table and the Georgian Tax Code. The text of the Belarus and Georgia convention and its signing date were not read; the conditions of the 5% and 10% dividend tiers are therefore not stated. Secondary: the National Bank of Georgia's 2022 sanctions instruction as reported by 1tv.ge. Our calculations assume the 13% rate on dividends below BYN 350,000 and a full credit for Georgian withholding; confirm with a Belarusian adviser. This is not legal or tax advice.