Georgia’s business-friendly tax environment continues to attract international attention, particularly among companies involved in cross-border trade. One of the most compelling incentives available is the Special Trading Company (STC) status. It is designed to support re-export activities through full exemption from corporate income tax. For businesses engaged in warehousing and foreign goods resale, this preferential regime presents a powerful opportunity. It helps reduce operational costs while leveraging Georgia’s strategic location and customs infrastructure.
What Is a Special Trading Company?
A Special Trading Company is a legal entity registered in Georgia. It operates under a tailored tax regime available only to newly established businesses that engage in specific types of international trading. The status is not granted automatically; it must be requested as part of the company’s registration process. The entity must be incorporated solely to carry out permitted STC activities.
Upon approval, the tax authority issues a certificate confirming Special Trading Company status. The certificate becomes effective from the company’s registration date. It remains in force until it is revoked in accordance with the law.
Activities Allowed Under Special Trading Company Status
The core purpose of the STC regime is to support re-export operations. Therefore, the list of permitted activities is specific and tightly controlled. Special Trading Companies may:
- Re-export foreign goods stored in a customs warehouse located in Georgia;
- Supply foreign goods within a customs warehouse, including transactions with other STCs and non-STC entities;
- Purchase foreign goods from non-STCs, provided that the transaction is carried out at or above the declared customs value and that the goods are either re-exported or sold within a customs warehouse.
Additionally, an STC may receive income from a limited range of other sources without jeopardizing its tax-exempt status. This includes:
- Income that is already exempt from corporate profit tax under the general provisions of Georgian tax law;
- Proceeds from the sale of fixed assets that have been used for at least two years in business operations;
- Other income, which on an annual basis must not exceed 1 million GEL and 5 % of the customs value of the imported foreign goods.
Tax Regime and Incentives for Special Trading Companies in Georgia
The main advantage of the Special Trading Company regime lies in its complete exemption from corporate income tax. Businesses with STC status do not pay the standard 15% profit tax. This applies to income generated from approved re-export and warehousing activities. This exemption is a major draw for international trading firms. It applies to those routing goods through Georgia without engaging in local distribution or services.
To preserve the integrity of the incentive, the law allows companies to earn a small portion of non-core income without disqualification, up to 1 million GEL annually or 5% of the customs value of imported goods. This provides flexibility for incidental revenue streams while ensuring that the STC remains focused on its primary trade functions.
At the same time, STCs are prohibited from participating in domestic commerce or providing services to Georgian residents. This ensures that the profit tax exemption is not used to gain an unfair advantage in the local market and remains targeted at cross-border activities that bring logistical and commercial flows into Georgia.
This regime underscores Georgia’s ambition to become a regional hub for trade and re-export while offering international companies a highly efficient tax environment for scaling their logistics operations.
How to Obtain Special Trading Company Status
The process of obtaining STC status is simple but must be initiated promptly. A company must submit an application to the Revenue Service within one month of its registration or before commencing any business activity. The application must include key corporate details such as the company name, registration number, legal address, and signature of an authorized representative.
Once submitted, the tax authority has five business days to review and issue a certificate of Special Trading Company status. If rejected, a written explanation must be provided within the same timeframe.
It’s important to emphasize that this status is only available at the formation stage, a precondition that ensures the company’s entire structure is built around STC-compliant activity.
How and When STC Status Can Be Revoked
A company may choose to relinquish its Special Trading Company status voluntarily. To do so, it must submit a written request to the Revenue Service at least five business days before the start of the new calendar year. The revocation takes effect from the beginning of the following year.
Upon receipt of an application requesting the withdrawal of special trading company status, the tax authority shall, within 10 business days, adopt a formal decision terminating such status, thereby bringing to an end all rights and privileges associated therewith.
Why Choose the STC Regime?
For companies engaged in global re-export, customs warehousing, or cross-border wholesale trading, Georgia’s Special Trading Company regime offers one of the most attractive tax setups in the region. With zero profit tax on qualifying activities, a transparent application process, and a well-defined operational framework, STC status helps businesses reduce their tax exposure while strengthening their international supply chains.
However, this is a niche incentive. Companies must be fully aligned with the permitted business model, and any deviation may result in loss of status. Proper legal and tax planning is essential.
About Andersen Georgia
At Andersen Georgia, we help international trading companies and logistics operators structure their businesses to take full advantage of Georgia’s tax incentive regimes. From initial company formation to obtaining STC certification and ensuring ongoing compliance, our team provides comprehensive legal and tax support every step of the way.
Contact us at tax@ge.andersen.com to learn how the Special Trading Company regime can benefit your global operations.
Disclaimer: This article reflects Georgian legislation and public information as of August 2025. Readers are advised to seek professional guidance tailored to their specific business before acting on the information provided.