Tax Publications

Substance Over Form Principle and Its Impact on Tax Obligations

Substance Over Form Principle and Its Impact on Tax Obligations

In practice, the legal form of a transaction may not always reflect its true economic substance. While in civil law such inconsistencies may be addressed through the concept of fraudulent transactions, in taxation, the issue can be approached differently. Under the Georgian Tax Code, the Revenue Service is authorized to reclassify a transaction for tax

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Taxation of Transactions between Development Companies and Landowners

Taxation of Transactions between Development Companies and Landowners

In Georgia’s fast-developing real estate sector, it is common for development companies and landowners to enter into complex contractual arrangements involving the exchange of land for completed residential or commercial spaces. While some transactions are structured as traditional sale-and-purchase agreements, barter arrangements are far more frequent in practice. Under such deals, the landowner transfers ownership

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Taxation of Foreign Currency Transactions in Georgia

Taxation of Foreign Currency Transactions in Georgia

In Georgia, many business transactions, such as loans, advance payments, or capital contributions, are carried out in foreign currency. While this practice is common in international commerce, it carries specific tax implications that depend on how such operations are reflected and valued for Georgian tax purposes. Under the Tax Code of Georgia, any taxable transaction

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Tax Obligations Related to Business Sale

Tax Obligations Related to Business Sale in Georgia

The sale of a business in Georgia can take two main forms: selling the company’s shares or selling its business assets. While both options ultimately transfer ownership and control, they differ substantially in their tax implications. Georgian tax law provides distinct treatment for each transaction type, especially under Personal Income Tax (PIT), Corporate Income Tax

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Tax Obligations upon Sale of Residential Property

Tax Obligations upon Sale of Residential Property

Introduction In Georgia, the taxation of real estate sales follows a simple and transparent framework. Unlike many other jurisdictions, Georgia does not impose a separate capital gains tax. Instead, profits from the sale of assets are taxed as ordinary income under either the Corporate Income Tax (CIT) or Personal Income Tax (PIT) regime, depending on

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investment funds taxation Georgia

How Investment Funds Are Taxed in Georgia: Exemptions, Dividends, and Capital Gains

Georgia offers one of the most tax-efficient frameworks in the region for structuring and managing investment funds. Owing to the rules outlined in the Tax Code of Georgia and the Law of Georgia on Investment Funds, both domestic and international investors can benefit from generous tax exemptions, clear pass-through treatment, and full relief on certain

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Tax Consequences of Capital Increase/Reduction

Tax Consequences of Capital Increase/Reduction

Capital increases and reductions are common corporate transactions in Georgia. While these actions primarily reflect changes in a company’s equity structure, they also carry specific tax consequences. Understanding how capital contributions and withdrawals are treated under Georgian tax law is essential for both shareholders and businesses to remain compliant and avoid unexpected liabilities. Tax Consequences

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Georgian Tax Residency and High Net Worth Individual (HNWI)

High Net Worth Individual (HNWI) Tax Residency in Georgia

Georgia has positioned itself as an appealing destination for globally mobile individuals, offering a unique route to tax residency designed specifically for High-Net-Worth Individuals (HNWIs). This program allows qualified applicants to obtain Georgian tax residency without meeting the usual physical presence requirement, making it an attractive option for investors, entrepreneurs, and affluent expatriates. General Rule

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Virtual Zone Person Status in Georgia (0% Corporate Tax Regime)

Virtual Zone Person Status in Georgia (0% Corporate Tax Regime)

What is Virtual Zone Person Status and Why is It So Beneficial? Georgia offers one of the most attractive tax regimes in the region for IT companies through its Virtual Zone Person (VZP) status. This designation grants qualifying tech companies a 0% corporate income tax rate on profits derived from the export of digital services

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