France
Georgia
France and Georgia have had a tax treaty since 2010, and Georgian company law welcomes a French owner like any other. The difficulty is a mismatch between the two systems: Georgia does not tax profit kept in the company, and French anti-avoidance rules are triggered precisely by low tax actually borne abroad.
This guide reads the treaty, then the two French rules that decide the case, article 209 B for a French company and article 123 bis for an individual.
What Georgia asks of a French founder
- One shareholder and one director, French or otherwise.
- No minimum capital for a limited liability company.
- An apostilled power of attorney with a Georgian translation. Since 1 May 2025, French apostilles are issued by the notarial profession.
- For a French parent company, a Kbis extract and articles, apostilled and translated.
The steps are in how to register a company in Georgia.
The 2007 treaty, read on the text
The convention was signed in Paris on 7 March 2007 and entered into force on 1 June 2010.
| Income from Georgia | Treaty | Georgian domestic rate | What applies |
|---|---|---|---|
| Dividend to a French company holding 50% or more and having invested EUR 3 million or more | 0% | 5% | 0% |
| Dividend to a French company holding 10% or more and having invested over EUR 100,000 | 5% | 5% | 5% |
| Dividend in other cases, including individuals | 10% | 5% | 5%, the domestic rate |
| Interest | Residence state only | 5% | 0% in Georgia |
| Royalties | Residence state only | 5% | 0% in Georgia |
France eliminates double taxation by a credit: Georgian tax on a dividend is credited against French tax on it, capped at the French tax (Article 24).
Tax estimate
How much tax could you save?Three questions, then the yearly difference between your current rate and three jurisdictions.
Article 209 B: a Georgian subsidiary of a French company
Article 209 B taxes a French company on the profits of a foreign entity it controls when that entity enjoys a privileged tax regime.
- Control: more than 50% of shares, financial or voting rights, directly or indirectly.
- Privileged: tax actually borne at least 40% below French corporate tax. With French tax at 25%, the line is 15%.
- Measured on tax actually borne, year by year, on profits recomputed under French rules.
Here Georgia's model matters. A Georgian company that reinvests its profit bears no profit tax at all that year. On a plain reading of the test, that is below the line. A year with a full distribution looks different, since the company then pays 15% of a grossed-up base. This is our reading of the general rule applied to a distribution model, not a published position of the French administration.
- 1Does the French company hold more than 50%?If not, 209 B does not apply on this basis
- 2Is Georgian tax borne 15% or less of French-computed profit?Likely yes in any year the profit is reinvested
- 3Does the safe harbour apply?Operations mainly with a purpose other than placing profit there; presumed for a real industrial or commercial activity in Georgia
- 4If notProfits deemed distributed and taxed in France, with credit for comparable Georgian tax
The safe harbour is the real answer. Article 209 B does not apply when the operations mainly have a purpose and effect other than placing profit in a low tax territory, presumed where the entity carries on an effective industrial or commercial activity in its own state. A Georgian company with staff, premises and Georgian or regional clients fits. A Georgian company that only invoices for work done in France does not.
Article 123 bis: shares held by a French individual
For a French resident individual, article 123 bis taxes the profits of a foreign entity as his or her own income each year, when three conditions are met together.
- A holding of 10% or more, counting family members.
- A privileged tax regime, measured as for companies.
- Assets that are mainly financial: securities, receivables, deposits.
The third condition keeps an operating Georgian company out. A Georgian holding or treasury company does not escape it. For an operating company, the French individual is taxed on dividends when paid, with a credit for the 5% Georgian withholding.
Bringing the profit home to a French company
A French parent can apply the parent and subsidiary regime (articles 145 and 216): the dividend is exempt, except a 5% share of costs taxed at the normal rate.
| Step on 100 of Georgian profit | Amount |
|---|---|
| Georgian distribution tax, 15% of the grossed-up base | 15.00 |
| Dividend paid | 85.00 |
| Georgian withholding, French company holding 10% and over EUR 100,000 | 4.25 |
| French tax: 5% of 85.00 taxed at 25% | 1.06 |
| Total tax, both countries | 20.31 |
- The stake must be at least 5% and kept two years.
- With 50% and EUR 3 million invested, the Georgian withholding drops to 0%, and the total to about 16.
If you move to Georgia
A French founder who leaves France for Georgia faces French rules on leaving: the domestic criteria of tax residence (home, main activity, centre of economic interests) and, for large shareholdings, the exit tax. The treaty's tie-breaker decides dual residence. Georgian residence and the source rules for work done in Georgia are in the tax guide for non-residents.
The bottom line
The France and Georgia treaty is favourable: no Georgian tax on interest and royalties, 0% to 5% on dividends to French companies. The risk is on the French side. A Georgian subsidiary that reinvests bears no tax, so a French parent must rely on the article 209 B safe harbour, which a real Georgian business meets and an invoicing shell does not. A French individual is exposed under article 123 bis only through a mainly financial company.
corpsec registers the Georgian company and provides its registered office. See the Georgia formation service, or read how Georgian profit tax works.
Frequently asked questions
Is there a tax treaty between France and Georgia?
Yes. It was signed in Paris on 7 March 2007 and entered into force on 1 June 2010. It limits Georgian tax on dividends to 0%, 5% or 10% and removes it on interest and royalties.
Does article 209 B apply to a Georgian subsidiary?
It can. A Georgian company that reinvests bears no profit tax that year, which is below the French 15% line. The safe harbour protects a subsidiary with an effective industrial or commercial activity in Georgia.
Can a French individual own a Georgian company?
Yes. Article 123 bis only applies if the company's assets are mainly financial. An operating company is outside it, and dividends are taxed in France when received, with a credit for Georgian withholding.
What does a French company pay on a Georgian dividend?
Under the parent and subsidiary regime, only tax on a 5% share of costs. On 100 of Georgian profit, total tax in both countries is about 20, or about 16 for a large holding that qualifies for 0% withholding.
How do I get French documents accepted in Georgia?
With an apostille, issued by the notarial profession since 1 May 2025, and a Georgian translation.
Sources
- France and Georgia tax convention signed in Paris on 7 March 2007, text published by the French tax administration: dividends at 0%, 5% or 10% (Article 10), interest and royalties taxable only in the state of residence (Articles 11 and 12), credit method (Article 24)
- BOFiP, BOI-INT-CVB-GEO: entry into force of the convention on 1 June 2010, after approval by Law 2010-202 of 2 March 2010 and publication by Decree 2010-582
- BOFiP, BOI-IS-BASE-60-10-20-20, version of 10 June 2026: a privileged tax regime means tax lower by 40% or more, measured on tax actually borne and against French corporate tax
- Service-Public.fr: French apostilles are issued by the notarial profession since 1 May 2025
- Tax Code of Georgia (consolidated 15 October 2026): no tax on retained profit, 15% on distribution with a base divided by 0.85, 5% dividend withholding
Official, read on 26 October 2026: the text of the 2007 convention and its protocol on impots.gouv.fr, and the BOFiP page on its entry into force; the Georgian Tax Code. Read on 5 October 2026 for this series: BOFiP BOI-IS-BASE-60-10-20-20 and articles 209 B, 238 A, 123 bis, 145 and 216 of the French tax code in a consolidated edition of 28 September 2026 built from Legifrance data. How the French administration compares tax actually borne by a company under Georgia's distribution model is our reading of the general rule, not a published position; confirm with a French adviser. French personal rates and social levies on dividends are not quoted because they were not checked on the day of writing. This is not legal or tax advice.