Georgia

Research notes

Georgia — family-office tax dossier

Last reviewed: 2026-10-16 Tax year: 2026 Reviewer: research agent (Claude), unreviewed by a tax adviser

Summary

Georgia is close to territorial for individuals. Income of a resident that does not have a Georgian source is exempt (Tax Code Art. 82(1)(u)), so foreign dividends and gains on foreign securities are untaxed. Georgian dividends bear a final 5% withholding. Gains on assets held more than two years (not used in business) are exempt; otherwise the rate is 20% (5% for a home or car). Property received as a gift or inheritance by first- and second-line heirs (children included) is exempt. No wealth tax. Residence comes from 183 days in a 12-month period, or by application as a 'high net worth individual'.

Residence and eligibility

Resident for the tax year if physically present 183+ days in any continuous 12-month period ending in that year (Art. 34(2)). Art. 34(6): residency may also be granted to a high net worth individual (as defined in the Law on Securities Market) under rules of the Minister of Finance; Art. 34(6^2) allows other foreigners to be granted residency by the Minister's rules.

• High net worth individual tax residency (Art. 34(6)) (EU, US, OTHER): Status granted on application to a high net worth individual (Art. 34(6) Tax Code; Minister of Finance Order No. 60 of 1 March 2023). Secondary sources (Revera, Eurofast/Mondaq, Expathub; the order itself was not opened) report property above GEL 3 million or income above GEL 200,000 a year for the last three calendar years, plus a link to Georgia (for example Georgian-source income of at least GEL 25,000 or real estate worth USD 500,000), renewed annually. It is a residence status, not a lower tax rate: a family that actually lives in Georgia is resident through the 183-day test and gets the same exemption of foreign-source income.
• Visa-free stay / residence permit (EU, US, OTHER): EU and US citizens can stay visa-free for long periods (commonly reported as one year; not verified); residence permits on investment in real estate are available (amount not verified).

Standard regime eligibility: 183+ days in Georgia in any continuous 12-month period ending in the tax year (Art. 34(2)), or residency granted as a high net worth individual (Art. 34(6)).

Capital gains

Gains from selling assets owned more than two years are exempt unless the asset was used in economic activity (Art. 82(1)(f.c)); merely holding shares for dividends is not economic activity. A home with its land held over two years is exempt (Art. 82(1)(f.a)). Otherwise gains are taxed at 20%, or 5% for a residential apartment/house or vehicle (Art. 81(3)). Gains without a Georgian source (e.g. foreign listed shares, foreign real estate) are exempt for residents (Art. 82(1)(u)).

JSON values: headline rate 20% (0.2); listed securities domestic 0% (0.0), foreign 0% (0.0); private business sale 0% (0.0); local real estate 0% (0.0); foreign real estate 0% (0.0).

• How the JSON numbers were derived: Held longer than 2 years: Georgian shares and private company shares 0% (Art. 82(1)(f.c)); Georgian residential property 0% (f.a); foreign securities and foreign real estate 0% (non-Georgian source, Art. 82(1)(u)). Within 2 years: 20% (5% residential). Headline = 20% general PIT rate.
• Holding periods: 2 years (Art. 82(1)(f)); holding periods of a parent/testator are added for a first-line heir (Art. 82(4)(a1)).
• Professional-trader risk: Assets used in economic activity do not get the 2-year exemption; frequent trading could be treated as economic activity (no guidance checked).
• Foreign assets: Non-Georgian-source income of resident individuals exempt (Art. 82(1)(u)).
• Tax year / confidence / verification: 2026 / high / verified (checked 2026-10-15)
• Sources: Tax Code of Georgia (Law No. 3591, consolidated version 30/09/2026); Georgia – Individual – Income determination; Georgia – Individual – Taxes on personal income

Dividends

Dividends paid by a Georgian company to an individual are taxed at source at 5% (Art. 130(1)), final. Foreign dividends are non-Georgian-source income and exempt for resident individuals (Art. 82(1)(u)).

JSON values: headline 5% (0.05); domestic 5% (0.05); foreign gross 0% (0.0); foreign tax relief: exemption.

• How the JSON numbers were derived: Domestic 5% final WHT; foreign 0% because exempt as non-Georgian-source income.
• Outbound withholding: 5% on dividends to non-residents (treaty 0–15%). Companies pay 15% profit tax on distributed profit.
• Treaty network: 58 treaties (PwC).
• Tax year / confidence / verification: 2026 / high / verified (checked 2026-10-15)
• Sources: Tax Code of Georgia (Law No. 3591, consolidated version 30/09/2026); Georgia – Corporate – Withholding taxes; Georgia – Individual – Taxes on personal income

Inheritance and gifts to children

No separate inheritance or gift tax. The value of property received as a gift or inheritance by first-line heirs (spouse, children, grandchildren, parents) and second-line heirs (siblings, nieces/nephews) is exempt from income tax (Art. 82(1)(g)). Third and fourth-line heirs are exempt up to GEL 150,000 a year; other gifts above GEL 1,000 are taxable at 20%.

JSON values: basis beneficiary, bracket mode marginal, children fully_exempt, exemption GEL 0, marginal brackets above the exemption: none; other transfer costs 0% (0); gifts same as inheritance: True; tax-free after years: None.

• Gifts: Gifts follow the same exemption (first/second-line heirs fully exempt).
• Business relief: No business relief relevant (children exempt or not researched). Covers listed portfolios: no.
• Domicile / residence rules: Income-tax based; applies to residents and to Georgian-source property for non-residents.
• Exemptions and thresholds: First/second-line heirs: fully exempt; third/fourth-line: GEL 150,000 a year; others: GEL 1,000 a year.
• Tax year / confidence / verification: 2026 / high / verified (checked 2026-10-15)
• Sources: Tax Code of Georgia (Law No. 3591, consolidated version 30/09/2026); Georgia – Individual – Other taxes
• Surviving spouse (spouse_treatment fully_exempt): Spouse is a first-line heir under the Tax Code (Art. 82), so the inheritance is exempt without limit or conditions.

Wealth tax

No net wealth tax. Property tax applies to individuals whose annual family income exceeds GEL 40,000 (on real estate, yachts, aircraft, cars) plus land tax.

JSON type: none.

• Property tax (not a wealth tax): Property tax for families with annual income above GEL 40,000 (rates not stated by PwC; up to about 1% of market value, unverified); separate land tax.
• Tax year / confidence / verification: 2026 / high / partially_verified (checked 2026-10-15)
• Sources: Georgia – Individual – Other taxes

Special regimes

None modelled; see the summary and open questions for regimes considered and rejected.

Company taxation (kept separate from personal tax)

Headline CIT rate in JSON: 15% (0.15).

Profit tax 15% (Art. 98(1)), levied on distributed profit (Estonian-style; Art. 97) rather than retained earnings; 20% for banks and lenders. 5% WHT on dividends.

Cost of living notes

City: Tbilisi (Vake, Mtatsminda, Tskneti, Lisi Lake, Okrokana, Shindisi, Kaklebi).

• Prime rent (monthly): USD 3,300 (2026). Median asking rent (USD 3,300, about GEL 8,580 at the portal's conversion) of 26 private houses for rent with 4–5 bedrooms and at least 200 m² in the prime/expat districts listed (range USD 1,000–9,000), from the first six pages (144 listings) of Myhome.ge's Tbilisi houses-for-rent search on 2026-10-15. Listings are mostly quoted in USD. Asking prices on a listing portal. Source: Private houses for rent in Tbilisi

• School (annual, per child): GEL 31,000 (2026). The Guivy Zaldastanishvili American Academy in Tbilisi (GZAAT), a selective private American-style high school (grades 8–12), 2026–2027 tuition for Grades 9–12 (Grade 8: GEL 19,500), plus a GEL 600 security deposit. From the school's own fee page; the International Schools Database lists the same 19,500–31,000 GEL range for 2026/2027. Source: GZAAT — Tuition Fee

QSI International School of Tbilisi, BIST and the European School still do not publish tuition, so the main expat schools may cost more than GZAAT.

Open questions

• Abkhazia and South Ossetia are outside government control.
• International school fee not published online by QSI Tbilisi, BIST (fee schedule supplied to applicants only) or the European School; only rent is sourced, so the cost metric is unscored. A fee schedule obtained from an admissions office would close this.
• (standard / capital_gains) How the source rules classify a gain on foreign shares held through a Georgian broker or custodian was not checked (source is generally the issuer's/asset's location).

US citizens: US citizens remain US-taxed; Georgia's near-zero tax on foreign income leaves nothing to credit. US–Georgia treaty status (1973 US–USSR treaty) not verified.

• Property tax on individuals above GEL 40,000 family income: secondary sources (Expathub, IBCCS, Revera) give 0.8%-1% of market value above GEL 100,000 of family income and 0.05%-0.2% between GEL 40,000 and 100,000; the Tax Code chapter on property tax was not opened and the thresholds differ between sources. On a EUR 5m home this could be EUR 40,000-50,000 a year; not modelled.

Sources

• Tax Code of Georgia (Law No. 3591, consolidated version 30/09/2026) — Legislative Herald of Georgia (Matsne) (legislation)
• Georgia – Individual – Income determination — PwC Worldwide Tax Summaries (professional)
• Georgia – Individual – Taxes on personal income — PwC Worldwide Tax Summaries (professional)
• Georgia – Corporate – Withholding taxes — PwC Worldwide Tax Summaries (professional)
• Georgia – Individual – Other taxes — PwC Worldwide Tax Summaries (professional)
• Georgia – Individual – Residence — PwC Worldwide Tax Summaries (professional)
• Clarifications from the Georgian Tax Service on the procedure for obtaining a tax resident certificate based on wealth — Revera Legal (professional)
• Private houses for rent in Tbilisi — Myhome.ge (TNET) (other)
• GZAAT — Tuition Fee, 2026-2027 (The Guivy Zaldastanishvili American Academy in Tbilisi, other): https://gzaat.org/admission/tuition-and-financial-assistance
• International Schools Database — Tbilisi (International Schools Database, other): https://www.international-schools-database.com/in/tbilisi

Change log

• 2026-10-15: initial research.
• 2026-10-15: phase 2 data-quality pass: added Tbilisi prime house rent (USD 3,300/month median of 26 prime-district 4-5 bedroom listings on Myhome.ge). International school fees are not published online (QSI, BIST), so the cost metric stays unscored.
• 2026-10-15: cost-of-living pass: re-tried school fees (QSI Tbilisi, BIST incl. its policy PDFs, European School, New School); none published online. Rent unchanged; metric still unscored.
• 2026-10-15 (household cost pass): added the GZAAT Grades 9–12 tuition (GEL 31,000, 2026–27, school's own page) as the school fee; with rent already sourced the metric can now be scored.
• 2026-10-15: family rent re-checked against the upper-middle-class standard: kept.
• 2026-10-16: added surviving-spouse treatment.
• 2026-10-16: 60-year recipe pass. Re-read Tax Code Art. 82(1)(u), (g), (f.a)-(f.c) and Art. 130(1) on Matsne: foreign-source income exempt, first/second-line heirs exempt, 2-year gains exemption, 5% dividend withholding all confirmed, no rate changed. Residency route for high net worth individuals updated from secondary sources (Order No. 60 of 2023); recorded the unverified property tax on homes. No special regime or holding structure added (the HNWI status changes residence, not tax).