Georgia’s tax legislation places significant importance on determining an individual’s tax residency status. In Georgia, residency rules apply regardless of whether the individual is a Georgian citizen, foreign national, or stateless person. The main method of obtaining Georgian tax residency is based on physical presence in Georgia, while Georgian legislation also provides an alternative pathway for certain individuals.
The 183-Day Rule for Georgian Tax Residency
Under the Georgian Tax Code, an individual is considered a tax resident for the current tax year if they are physically present in Georgia for at least 183 days during any continuous 12-month period ending in that year. This rule applies equally to Georgian citizens, foreign nationals, and stateless persons.
The 183-day requirement is therefore based on the individual’s actual physical presence in Georgia rather than their citizenship. Once the applicable presence requirement is met, the individual may qualify as a Georgian tax resident for the relevant tax year.
It is worth noting that the relevant 12-month period does not have to coincide with the calendar year. Because the period is any continuous 12 months ending in the tax year in question, days spent in Georgia in the previous calendar year may also be taken into account. Residency status is determined separately for each tax year, meaning that an individual may be a Georgian tax resident in one year and not in another. Notably, any day of presence in Georgia counts, irrespective of duration, including the days of arrival and departure.
Certain periods of presence in Georgia are excluded when determining whether the 183-day threshold has been met. These include periods spent in Georgia in a diplomatic or consular capacity, including by accompanying family members, as an employee of an international organization under an international treaty, while transiting from one foreign country to another, and for medical treatment or vacation.
Alternative Pathway for Tax Residency
In addition to the standard 183-day rule, Georgian legislation provides an alternative pathway for individuals who do not meet the physical presence requirement but have substantial wealth and economic ties to Georgia. This pathway is available under rules established by the Minister of Finance of Georgia and is generally relevant to High-Net-Worth Individuals (HNWIs).
Who qualifies as an HNWI
An individual is treated as a High Net Worth Individual if either of the following applies:
- their confirmed property exceeds 3 million GEL; or
- their annual income in each of the last three years exceeded 200,000 GEL.
Additional requirements
Meeting the HNWI definition alone is not sufficient. In addition, the applicant must own property in Georgia worth at least the equivalent of USD 500,000 in GEL, and must either:
- hold a valid Georgian residence permit, residence card, or Georgian citizen’s ID card; or
- have received at least 25,000 GEL in Georgian-source income in the tax year preceding the application.
These conditions are intended to ensure that the applicant has both substantial wealth and a genuine economic connection to Georgia.
Application and duration
Applications are submitted to the Revenue Service in person, through an authorized representative, or electronically, together with supporting documentation such as proof of wealth or income, property valuation reports, and evidence of Georgian-source income where relevant. If the application meets the legal requirements, the Revenue Service forwards it to the Minister of Finance of Georgia within seven working days with a proposal to grant tax residency. Where deficiencies are identified, the applicant is given time to correct them.
HNWI tax residency is granted for a single tax year. Maintaining the status requires a new application with updated documents each year, confirming continued compliance with the requirements.
Tax Residency Certificate in Georgia
Once an individual qualifies as a Georgian tax resident, obtaining documentation confirming their tax residency may be important for cross-border tax purposes.
A tax residency certificate serves as official confirmation of an individual’s Georgian tax residency status. It may be relevant when dealing with foreign tax authorities, applying tax treaty provisions, or demonstrating that an individual is a tax resident of Georgia.
The certificate is issued by the Georgian Revenue Service upon application, and is generally issued for a specific tax year.
Why the 183-Day Rule Is Important
The 183-day rule reflects a widely recognized approach to determining individual tax residency, under which an individual’s actual physical presence in a country may establish a basis for tax residency. Georgia applies this principle by linking tax residency to an individual’s presence in Georgia for at least 183 days during the relevant continuous 12-month period.
The underlying concept is that an individual’s actual and sustained presence in a country may indicate a meaningful connection with that country for tax purposes. Similar physical-presence rules are also used by many other countries when determining individual tax residency.
Residency status also has practical consequences. Georgia applies a territorial approach to the taxation of individuals, under which income of a resident individual that is not Georgian-source income is generally exempt from personal income tax. Determining residency status correctly is therefore relevant both for Georgian tax purposes and for an individual’s tax position in other jurisdictions.
Disclaimer: This article is based on Georgian legislation and publicly available information as of August 2026 and is intended for informational purposes only. It does not constitute legal or tax advice. Readers should seek professional guidance tailored to their specific circumstances before taking action based on this information.