Georgia Tax for Non-Residents 2026: Really Territorial?

Georgia is often described as a territorial tax system: foreign income is not taxed, only Georgian income is. That is a fair summary for some people and a costly misreading for others, in particular the freelancer who moves to Tbilisi and keeps working for foreign clients.

This guide covers three situations separately: the foreign owner of a Georgian company, the foreign company paid by a Georgian one, and the individual who lives in Georgia. Each answer comes from the Tax Code.

183days in any 12 months make an individual Georgian resident

5%withholding on dividends, interest and royalties paid abroad

10%withholding on other Georgian-source payments to non-residents

15%the same payments to a preferential tax country

Three situations, three sets of rules

The foreign owner of a Georgian company

As a shareholder living abroad, you meet Georgian tax twice, both times when profit is distributed.

• At company level: 15% on the grossed-up distribution, or 17.65% of the net dividend, as shown in the corporate tax guide.
• At source on the dividend: 5% withheld when the dividend is paid to an individual or a foreign company (Article 130(1)).
• Nothing more in Georgia. A non-resident individual without a permanent establishment is taxed only at source on Georgian income (Article 80(3)).

What happens next is decided at home. Your country may credit the Georgian tax, may tax the dividend fully, or may tax the company's profit before any dividend under controlled foreign company rules. A tax treaty with Georgia can reduce the 5% withholding; check the treaty for your country.

The foreign company paid by a Georgian company

When a Georgian company pays a foreign supplier that has no permanent establishment in Georgia, it withholds tax at source on Georgian-source income (Article 134).

Dividend5%

Interest or royalty5%

Other Georgian-source income10%

Same, preferential tax country15%

Two practical consequences:

• Management fees to the owner's foreign company are only taxable at source if they are Georgian-source income. Services rendered abroad by a foreign company with no presence in Georgia are generally not. Services rendered in Georgia are.
• A refund route exists. A non-resident taxed at source on these payments can file a return by 1 April of the following year and ask for recalculation on a net basis (Article 134(3)).

The individual living in Georgia

When you become resident

Article 34 makes an individual resident for the whole tax year if he or she was present in Georgia for 183 days or more in any continuous 12-month period ending in that year.

• A day counts if you were in Georgia at any time that day.
• Time abroad counts as presence when it is for treatment, leisure, a business trip or education (Article 34(3)).
• Some time in Georgia does not count: diplomats, international organisations, transit, and, in the English text, time spent "for treatment or leisure" (Article 34(4)).
• Other routes: residence can be granted to a high net worth individual, or by decision of the Minister of Finance (Article 34(6) and (6-2)).

Where the guides differ on the 183 days

Some guides count 183 days per calendar year. The Code counts them in any continuous 12-month period ending in the tax year, which can catch someone who spread a stay across two years. The English text of Article 34 also both counts time abroad for leisure as presence and excludes time in Georgia for leisure; ask an adviser how the Revenue Service applies the two paragraphs to you.

1. 1
   Is the income Georgian-source?Work done in Georgia, Georgian clients, Georgian company dividends: taxed whatever your residence
2. 2
   If not, are you resident in Georgia?183 days in any continuous 12 months
3. 3
   Resident with foreign passive incomeAdvisers report it is generally not taxed in practice; confirm for your income type
4. 4
   Non-resident with foreign incomeOutside Georgian tax

The freelancer trap: foreign clients, Georgian income

The "territorial" story breaks for people who work from Georgia. Article 104(1)(c) treats services as delivered in Georgia, and so as Georgian-source income, in two cases that matter here:

• (c.a) The service is actually rendered in Georgia. Writing code in Tbilisi for a client in Berlin is a service rendered in Georgia.
• (c.g) The provider is a Georgian resident and the client is abroad, unless the provider delivers through a permanent establishment in another country.

So a freelancer who lives in Georgia and invoices foreign clients has Georgian-source income. As an individual entrepreneur with small business status, that income can be taxed at 1% within the ceiling, as set out in the company types guide. Without the status, the standard rate is 20% (Article 81). It is not tax-free.

Foreign passive income of a resident

Advisers widely report that a resident individual's foreign-source passive income, such as dividends from a foreign company or foreign interest, is in practice not taxed in Georgia. We did not locate the provision in the English consolidated Code on the day of writing. If this is the reason you are moving, get written confirmation for your income type before relying on it.

Your home country decides the rest

Georgian rules are only half of any plan. Three home-country rules undo most structures built on Georgian rates alone.

• Controlled foreign company rules can tax a Georgian company's profit in your hands before any dividend.
• Place of effective management: a company run from your home country may be resident there.
• Exit and residence rules: leaving your home country for tax purposes usually takes more than 183 days in Georgia.

The country-specific guides cover these for Russia, Germany, France and the other origins in this series.