Georgia continues to position itself as one of the most attractive jurisdictions in Eastern Europe for technology and service-based businesses. Among the country’s standout incentives is the International Company Status. It’s a preferential tax regime designed specifically for companies engaged in Information Technology and Maritime Services.
This regime, introduced by amendments to the Georgian Tax Code and further detailed in Government Resolution No. 619, offers significant tax relief and legal stability. It also provides long-term benefits for companies that meet clearly defined eligibility criteria. From reduced income and salary tax rates to exemptions on property and dividends, the International Company Status is an ideal fit for globally oriented service firms with operational substance in Georgia.
What Is International Company Status?
International Company Status is a special designation granted to Georgian enterprises. It applies to those operating within narrowly defined sectors, namely, information technology and maritime services. This status enables qualified companies to benefit from a low-tax environment. To retain it, they must engage solely in permitted activities and maintain a genuine economic presence in Georgia.
The regime is intended to attract foreign investment and international business operations by offering predictability and clear tax advantages. Once granted, the status is valid indefinitely, subject to continued compliance with all regulatory requirements.
Who Is Eligible to Apply?
To qualify for International Company Status, a business must first be a legal entity registered in Georgia. This is typically a limited liability company (LLC). In addition, one of the following experience-based criteria must be met:
- The enterprise has at least 2 years of experience in the permitted activity for which it is applying for the status.
- The enterprise represents a non-resident company in Georgia, provided the non-resident company has at least 2 years of experience in the permitted activity being performed by the Georgian entity.
- More than 50% of the enterprise is owned by partner companies that, independently (each partner separately), have at least two years of experience in the permitted activity being carried out by the Georgian enterprise and for which the status is being requested.
The company must perform its income-generating operations from within Georgia. This means more than simply registering an office. It requires meaningful local presence, such as employing qualified personnel and incurring related operational expenses in the country. The activities must consist of key value-generating functions rather than administrative or auxiliary services.
International Company Status and Virtual Zone Status cannot be held simultaneously. If a company currently has Virtual Zone Status and is granted International Company Status, the former will be automatically revoked.
Permitted Activities Under the Regime
International Company Status is available only to entities conducting strictly defined business activities. These fall into two categories:
Information Technology Services:
This includes a broad range of digital and technical activities. Examples are software development and publishing, IT consulting, and system administration. It also covers web hosting, cloud services, remote technical support, and the provision of digital content, including software updates and downloads. All income must be generated exclusively through service contracts involving these permitted activities.
Maritime Services:
These are limited to commercial and technical ship management functions in line with international maritime standards (e.g., BIMCO ShipMan 2009). Qualified activities include voyage planning, fuel logistics, port coordination, vessel maintenance oversight, regulatory compliance, and provisioning. However, it excludes direct shipping or transportation services.
For both IT and Maritime service providers holding International Company Status, income from non-permitted activities must be limited. It must not exceed 2% of the company’s total revenue from permitted activities.
Tax Benefits of International Company Status
Businesses granted International Company Status enjoy some of the most competitive tax rates in the region. The tax incentives include:
- Corporate Income Tax (CIT): 5% (applied only upon profit distribution, as per Georgia’s Estonian-style tax system);
- Personal Income Tax (PIT) on Salaries: 5% for employees working for the international company;
- Withholding Tax (WHT) on Dividends: 0% on dividends distributed by an international company is exempt from withholding tax and is not included in the recipient’s gross income.
- Property Tax: 0% on property (excluding land tax) used for permitted business activities.
These incentives significantly reduce the overall tax burden for companies with operational substance in Georgia and help attract international entrepreneurs and established foreign businesses alike.
Reducing the Taxable Base of Distributed Profit Under International Company Status
One of the highly valuable features of Georgia’s International Company Status is the ability to reduce the taxable base of distributed profit by accounting for certain qualifying expenses.
In particular, the following expenses, when incurred within Georgia and properly documented, can reduce the amount of profit subject to the 5% corporate income tax upon distribution:
- Salaries paid to Georgian citizen resident employees directly employed by the international company;
- Costs related to scientific research, design, and experimental-construction services that are directly connected to the company’s permitted activities. These may include R&D expenditures, technical design work, prototype development, and other innovation-related services.
When such expenses are aligned with the company’s core operations and supported by valid documentation, they may be deducted from the distributable profit before calculating the tax, which can further reduce the CIT burden below 5%.
How to Apply for International Company Status
To apply for international company status, the interested person must submit an application (in written or electronic form) to the Revenue Service, using the form approved by the Minister of Finance.
The application must be accompanied by documentation/evidence proving the performance of the permitted activity. In the case of a permitted activity, the relevant permit must be provided. If necessary, the Revenue Service is authorized to request additional information from the applicant.
The decision to grant or reject the status is made by the Government of Georgia. The Government issues a decree granting international company status. The status is granted for an indefinite term and is considered effective from the beginning of the month in which it is granted.
Grounds for Revocation of the Status
Although International Company Status is granted indefinitely, the government retains the authority to revoke it under several conditions. Understanding these is crucial for maintaining compliance:
- If the company submits a written request for revocation, the status will be canceled from the beginning of the month in which the decision is made.
- If the company is granted Virtual Zone Person status, International Company Status is automatically revoked from the moment the new status takes effect.
- If legal amendments are introduced that alter the framework, revocation is effective from the date the amendments enter into force.
- If the company engages in non-permitted activities that exceed the 2% income threshold, the status is revoked retroactively from January 1 of the year in which the unauthorized activity began.
- If the company fails to maintain the operational requirements or no longer qualifies under the eligibility criteria defined by the government resolution.
Revocation can have significant tax consequences, including a shift back to Georgia’s standard corporate income tax regime, so companies are encouraged to monitor compliance regularly and maintain clear records of activities, staffing, and revenues.
Is International Company Status Right for Your Business?
Georgia’s International Company regime is tailored for companies with an established track record, a clear export-oriented model, and a willingness to establish a real operational presence in the country. It is particularly suited for:
- IT and software companies serving global clients;
- Maritime service providers managing fleets or shipping operations;
- Tech firms scaling operations with Georgian-based employees.
With transparent rules and generous tax incentives, International Company Status offers a long-term, stable environment for growth, especially for businesses that plan to expand their presence in Georgia while optimizing their international tax structure.
Note: This article is based on Georgian legislation and public data as of July 2025. Companies are encouraged to seek professional tax advice tailored to their specific circumstances before relying on the regimes described above.