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Georgia Company Setup from India 2026: ODI, LRS and Tax

Owning a Georgian LLC from India: the ODI and LRS routes, 20% TCS above ten lakh, the 2011 India and Georgia tax treaty, POEM risk, and the visa before flying.

Charles Martin
Charles MartinFounder, CorpSec
Updated October 20269 min read
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Georgia lets an Indian citizen own and direct a company with no local partner and no capital. The Georgian side takes a day. The Indian side decides whether the plan is legal, what it costs to send the money, and where the profit is finally taxed.

This guide puts the two sides together: which Indian route fits a Georgian company, what India collects before the money leaves, what the 2011 tax treaty changes and what it does not, and the visa question if you plan to go in person.

The India to Georgia corridor in four figures
$250kper financial year an Indian resident may remit under the LRS
20%TCS on investment remittances above ten lakh rupees
10%treaty ceiling on dividends, above Georgia's own 5%
GEL 0minimum capital of a Georgian LLC
Source: RBI Liberalised Remittance Scheme; Finance Bill 2026 memorandum; India and Georgia tax treaty (2011); Tax Code of Georgia

What Georgia asks of an Indian founder

Very little, by design.

  • One shareholder and one director, both of whom can be Indian residents.
  • No minimum capital for a limited liability company.
  • Registration through a representative with a notarised, apostilled power of attorney. India has applied the Apostille Convention since 2005.
  • A legal address in Georgia.

The steps are in how to register a company in Georgia. Unlike some Gulf jurisdictions, Georgia does not require a parent company: an individual can own the LLC directly. That matters for the Indian rules below.

Three Indian starting points

You areIndian routeFit with Georgia
An Indian company, LLP or registered firmOverseas Direct Investment (ODI)Good: a Georgian LLC is a limited liability operating entity
A resident individualODI through the Liberalised Remittance Scheme (LRS)Good for a direct operating company; not for a holding with a subsidiary
An Indian who has moved abroad and is no longer residentOutside the LRS limitsYour new country's rules apply instead

Route one: an Indian company invests under ODI

Under the Reserve Bank's Overseas Investment Directions of August 2022, an Indian entity may invest abroad without prior approval if the conditions hold.

  • The investor is an Indian entity: a company, an LLP or a registered partnership firm. A sole proprietor is not one.
  • The Georgian company has limited liability, which an LLC does.
  • The activity is a bona fide business, outside the short list of prohibited activities.
  • Form FC is filed through your bank before the remittance.
  • An Annual Performance Report is due every year by 31 December.

The amount is capped by reference to net worth, widely stated as 400% of the last audited net worth. We did not open the Rules to confirm that figure.

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Route two: a resident individual under the LRS

A resident individual may remit up to USD 250,000 per financial year, April to March, for all purposes combined. Investing in a foreign company is a permitted use.

India allowsIndia does not allow
Shares in an operating foreign companyA foreign company engaged in financial services
Control of that operating companyControl of a foreign company that has a subsidiary
Investing alone or with other resident individualsRemitting through a company, firm, HUF or trust
Up to USD 250,000 a yearRemitting without a PAN

A Georgian LLC that trades directly fits this table. A Georgian holding that you control and that owns a subsidiary does not: "control" starts at 10% of voting rights, and an individual may not control a foreign entity with a subsidiary. Keep the Georgian company as the operating company, not as a holding.

Choosing the Indian route for a Georgian LLCThe structure that works is the simplest: one operating company, owned directly.
  1. 1
    Do you run an Indian company, LLP or firm?Invest through it under ODI, Form FC through your bank
  2. 2
    Investing personally?Use the LRS, up to USD 250,000 a year, PAN required
  3. 3
    Will the Georgian company own a subsidiary?As an individual, not allowed if you control it
  4. 4
    Is the activity financial services?Closed to individuals under the LRS
Source: RBI Overseas Investment Directions 2022; RBI Master Direction on the LRS

The tax collected before the money leaves India

LRS remittances carry tax collected at source (TCS), collected by the bank at the time of transfer under section 394(1) of the Income-tax Act 2025, the former section 206C(1G).

LRS remittances in a financial yearTCS
Up to ten lakh rupees in totalNil
Above ten lakh, education or medical treatment2% since 1 April 2026
Above ten lakh, any other purpose, investment included20%
  • TCS is a payment on account, credited against your Indian tax in your return.
  • The threshold rose from seven to ten lakh on 1 April 2025.
  • It does not apply to a company's ODI remittance, since the LRS is for individuals.

Funding a Georgian LLC in stages, under ten lakh where possible, keeps cash flow simpler. It does not change the tax you finally owe.

The India and Georgia tax treaty

India and Georgia signed a tax treaty in New Delhi on 24 August 2011. It entered into force on 8 December 2011 and applies in India from 1 April 2012.

Income from Georgia to IndiaTreaty ceilingGeorgian domestic rateWhat applies
Dividends10%5% withholding5%, the lower domestic rate
Interest10%5% withholding5%
Royalties10%5% withholding5%
Fees for technical services10%10% on Georgian-source services10%
Treaty ceiling against what Georgia actually withholdsOn dividends, interest and royalties the Georgian domestic rate is already below the treaty ceiling.
Treaty ceiling, dividends10%
Georgian withholding, dividends5%
Treaty ceiling, royalties10%
Georgian withholding, royalties5%
Source: India and Georgia tax treaty (2011); Tax Code of Georgia, Articles 130, 131 and 134

Two points the treaty does not settle.

  • The Georgian distribution tax. Before a dividend is paid, the Georgian company pays 15% on the grossed-up distribution, as explained in the corporate tax guide. That is a tax on the company, and whether India gives an individual any credit for it is doubtful. Ask your adviser before you model the return.
  • The treaty has an anti-abuse clause. Its benefits are meant for genuine residents of the two countries.

Where the company is really managed

India treats a foreign company as resident if its place of effective management is in India. A Georgian LLC whose decisions are all taken by its owner in Bengaluru can be argued to be an Indian company for tax purposes, which undoes the reason to have it.

  • Hold board decisions where the director is, and minute them.
  • Give the Georgian company real activity: contracts, invoices and a bank account in Georgia.
  • If you relocate to Georgia, your Indian residence status changes the analysis; see the tax guide for non-residents.

Travelling to Georgia on an Indian passport

You do not need to travel to register. You may want to, for the bank account.

  • With a valid visa or residence permit from the United States, the United Kingdom, a Schengen state or another listed country, Indian citizens are reported to enter Georgia without a Georgian visa, for up to 90 days in any 180.
  • Without one, apply for a Georgian e-visa or at a consulate.
  • Reports of refused entry at Tbilisi airport circulate. Carry your company documents, hotel booking and return ticket.

Check the current rules on the official e-visa portal before booking. The bank step is covered in the business bank account guide.

The bottom line

Georgia suits an Indian founder who wants a simple foreign operating company: one LLC, owned directly, funded through ODI or the LRS. Avoid a Georgian holding over a subsidiary if you invest as an individual, budget for 20% TCS above ten lakh, and keep the company genuinely managed where its director is.

corpsec registers the Georgian LLC and provides its registered office; your Indian bank and chartered accountant handle the ODI or LRS filings. See the Georgia formation service, or check the full first-year cost.

The CorpSec package
See Georgia pricing

Frequently asked questions

Can an Indian citizen open a company in Georgia?

Yes. Georgia allows a single foreign shareholder and director, with no minimum capital and no local partner. Registration can be done through a representative with a notarised and apostilled power of attorney.

Can an Indian resident individual invest in a Georgian company?

Yes, under the Liberalised Remittance Scheme, up to USD 250,000 per financial year, in an operating company. An individual may not control a foreign company that has a subsidiary, so keep the Georgian LLC as the operating company.

Is TCS charged on money sent to fund a Georgian company?

Yes, for individuals under the LRS: nil up to ten lakh rupees in a financial year, then 20% for investment purposes, collected by the bank as a payment on account of your Indian tax.

Does India have a tax treaty with Georgia?

Yes. It was signed on 24 August 2011, entered into force on 8 December 2011 and applies in India from 1 April 2012. It caps dividends, interest, royalties and technical fees at 10%, while Georgia's own withholding on the first three is 5%.

Do Indians need a visa for Georgia?

Indian citizens holding a valid US, UK, Schengen or other listed visa or residence permit are reported to enter without a Georgian visa for up to 90 days in 180. Others apply for an e-visa or at a consulate. Check the official portal before travelling.

Can I run the Georgian company from India?

You can, but if its effective management is in India, India may treat it as an Indian tax resident. Keep decisions, contracts and activity genuinely located with the company.

Sources

Official, read for this series on 5 October 2026: the Reserve Bank of India's Overseas Investment Directions of 2022 and its Master Direction on the Liberalised Remittance Scheme, and the memoranda to the Finance Bills of 2025 and 2026 for tax collected at source. The India and Georgia treaty dates and rates come from the Indian notification as reproduced by Indian tax publishers, not reopened at the source. Official Georgian rules (company law, Tax Code) are those read for the other guides of this series on 26 October 2026. Secondary and to confirm on evisa.gov.ge or with the Georgian embassy: the visa rules for Indian citizens. Not read: the Overseas Investment Rules themselves, so the corporate limit of 400% of net worth is reported as widely stated. The treatment of the Georgian distribution tax in an Indian return is a question for your adviser. This is not legal or tax advice.

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