The Tax Code of Georgia places significant importance on determining a person’s tax residency. In Georgia, persons are generally taxed based on their residency rather than their citizenship. Different rules apply to individuals and legal entities for determining residency status. These rules are designed to identify where a person carries out most of their economic activities. The tax treatment differs for residents and non-residents.
Residency Rules for Individuals
General Rule for Obtaining 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. Residency applies equally to Georgian citizens, foreign nationals, and stateless persons.
Certain periods of presence are excluded from the calculation, including time spent in Georgia:
- In a diplomatic or consular capacity (and for accompanying family members),
- As an employee of an international organisation under an international treaty,
- While transiting from one foreign country to another,
- For medical treatment or vacation.
The Exception: High Net Worth Individual Tax Residency
Georgia’s tax legislation provides an alternative pathway for individuals who may not meet the 183-day presence rule. A High-Net-Worth Individual is defined as someone whose verified property exceeds 3 million GEL, or whose annual income over each of the last three years exceeds 200,000 GEL.
Such individuals may be granted Georgian tax residency based on economic ties, even without prolonged physical presence, in accordance with rules set by the Minister of Finance.
Key Eligibility Requirements
To qualify for Georgian tax residency under the HNWI program, applicants must:
- Meet the wealth or income threshold, either 3 million GEL in global assets or 200,000 GEL in annual income for the past three years.
- Own property in Georgia worth at least the equivalent of USD 500,000 in GEL.
- And the person 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 before applying.
These conditions ensure that HNWIs have both substantial wealth and a meaningful economic connection to Georgia.
Application Process for HNWI Tax Residency
Applications are submitted to the Revenue Service, either in person, through an authorised representative, or electronically. All supporting documents must be provided, including proof of wealth or income, property valuation reports, and evidence of Georgian-source income if applicable.
If the Revenue Service determines that the application and supporting documents fully meet the legal requirements, it must, within seven working days, forward the case to the Minister of Finance of Georgia with a proposal to grant Georgian tax residency. If deficiencies are found, the applicant is notified and given up to 30 days to correct them. Failure to correct the deficiencies within the deadline is treated as an application withdrawal, although the individual may reapply at a later date.
Residency is granted on an annual basis. Renewal requires submitting updated documents each year, demonstrating continued compliance with the program’s requirements.
Residency Rules for Businesses
Georgian legislation provides different rules for businesses to determine their residency status. According to the Tax Code of Georgia, a Resident Business is a Georgian enterprise or a Georgian organisation.
An enterprise includes the following entities that carry out economic activities or are established for the purpose of carrying out economic activities:
- Legal entities established in accordance with the legislation of Georgia;
- Corporations, companies, firms, and other similar entities established under the legislation of a foreign country, regardless of whether they have the status of a legal entity, as well as a permanent establishment of a foreign enterprise;
- Associations, partnerships, and other similar entities.
Accordingly, an individual entrepreneur is not considered an enterprise. The mere fact of registration as an individual entrepreneur does not give rise to tax residency for such a person. Likewise, obtaining small business status (1% tax regime), which is granted only to individual entrepreneurs and not to enterprises, does not automatically result in Georgian tax residency. Therefore, individual entrepreneurs (including those holding SBS) are subject to the residency rules applicable to individuals (see above).
Organisations, unlike enterprises, are mainly non-commercial legal entities and associations, and their primary activity is not conducting business.
An enterprise is considered a Georgian enterprise if its place of activity and/or place of management is in Georgia.
The place of activity of an enterprise is the place of its state registration, and in the absence of such registration, its legal address.
If an enterprise carries out activities without state registration and its founding documents do not specify the place of activity, the place of activity shall be considered the place where its main economic activity is carried out.
As for the place of management, it is considered to be the place of effective management of the enterprise, meaning the place where, in accordance with the founding documents (charter, agreement, regulations), the directorate (or other governing body) performs management functions, regardless of the location of the highest supervisory bodies of the enterprise or the place where income from activities is generated, unless otherwise provided by law.
Accordingly, for businesses, the determination of residency primarily depends on whether the enterprise is registered in Georgia, whether it conducts activities within the territory of Georgia, and from where the enterprise is effectively managed. If an enterprise has either its registration or place of management in Georgia, it will be considered as Georgian tax resident.
Disclaimer: This article is based on Georgian legislation and publicly available information as of February 2026 and is intended for informational purposes only. It does not constitute legal or tax advice.