Debt-to-Equity Reclassification in Georgia: Insights into the Revenue Service’s Approach
In October 2024, Georgia introduced a landmark change to its transfer pricing framework, one that significantly reshapes the way cross-border financing arrangements are evaluated. With the addition of Article 141 to Order №423 of the Ministry of Finance, the Revenue Service has been granted explicit authority to reclassify certain loans as equity contributions. This change […]
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