International Company Status in Georgia: 5% Profit Tax

Below are the rates as written in the Tax Code, the eligibility conditions, the list of permitted activities and the filing procedure.

What the status actually gives you

All four reliefs sit in article 23 of the Tax Code of Georgia rather than in secondary regulation. That matters: the rate does not depend on an inspector's discretion.

Profit tax stays distribution based, as in the general regime: it arises on distribution, not on accrual. The calculation is set out separately: taxable profit is determined by dividing the payment or cost by 0.95.

The property tax exemption is not automatic. It applies only where the property is used in activities permitted by the government resolution. Land is outside the exemption.

Dividends escape withholding and also drop out of the recipient's income

These are two separate consequences, and the second one is usually missed. The Tax Code excludes such dividends from the recipient's gross income. An individual who receives dividends from an international company therefore does not top up tax on them in a personal return. How dividends work under the general regime is covered in our guide to taxes in Georgia.

Source note

> "The profit tax rate for an international company shall be 5%." > > "The income earned as a result of working for hire at an international company shall be taxed at 5%." > > "A dividend paid by an international company shall not be taxed at the source."

Source: Tax Code of Georgia, article 23, paras 7, 8, 10

Who qualifies

The conditions sit in Government of Georgia Ordinance No 619 of 8 October 2020. They fall into two blocks: track record and real presence.

Track record. At least two years of experience in the permitted activity is required. Three routes are allowed:

1. The Georgian enterprise itself has two years of experience in the permitted activity.
2. The Georgian enterprise represents a non-resident that holds such experience.
3. More than 50% of the shares belong to partner enterprises, each of which independently has two years of experience.

Real presence. The ordinance requires the company to carry out its basic income generating activity in Georgia, to have adequate human resources with the necessary qualifications, and to cover appropriate operating costs. Registering an office on paper is not enough.

Salary paid to a hired citizen of Georgia is separately listed as a deductible expense.

Income from outside the permitted list is capped at two percent

This is the strictest condition and the most common reason the status is lost. Income unrelated to the permitted activities must not exceed 2% of the income from permitted activities, excluding VAT. Advisers often state this the other way round, as "98% of revenue from permitted activity", which means the same thing.

The practical consequence: any side income, from subletting space to a one off consultation outside the list, eats into that two percent headroom.

The latest amendment, Ordinance No 420 of 24 September 2025, left these conditions unchanged. It touched the procedure: the decision to grant the status is now also sent to the Georgia Innovation and Technology Agency, and being granted innovative startup status became a ground for terminating international company status. The two regimes cannot be combined.

Which activities count as permitted

The IT list is annexed to the ordinance and tied to economic activity codes:

• Software publishing, code 58.2, including computer games (58.21) and other software (58.29)
• Computer programming, consultancy and related activities, code 62, including 62.01 through 62.03 and 62.09
• Delivery of digital products, website development, web hosting, remote system administration
• Online access to software and to updates

Commercial and maintenance services for shipowners form a separate block in the list, which is the maritime side of the regime.

The list is closed and tied to a service contract. Activity that looks like IT but falls outside the codes is not inside the regime.

How this differs from the Virtual Zone

Both regimes are preferential and both target IT, but they are built differently. The Virtual Zone exempts profit from tax on software exports and is easier to obtain, with no two year track record and no government decision. International company status gives less on profit tax (5% against 0%) but adds relief on salaries and on property, which the Virtual Zone does not have.

A full breakdown of the first regime, including its limits, is in the piece on Virtual Zone status in Georgia. The choice turns on your cost structure: if payroll in Georgia is the bulk of your spending, 5% on salaries can outweigh a zero rate on profit.

How to file

The procedure runs through three bodies, and the tax authority is not the one that decides:

1. The application goes to the Revenue Service under the Ministry of Finance.
2. The Revenue Service reviews it within 10 days and passes it to the Ministry of Finance.
3. The Ministry sends the documents with a proposal to the Government of Georgia, which grants or refuses the status.

The status is granted for an indefinite term by government ordinance. It ends at the company's own request or when the company stops meeting the conditions.

The company must already be registered in Georgia before filing. Which form to pick, and how an LLC differs from a sole trader, is set out in the comparison of business structures in Georgia. A sole trader cannot hold this status: the rules speak of an enterprise with shares.

Frequently asked questions

Can a newly registered company obtain the status?

Not on its own track record, unless it already has two years of experience in the permitted activity. The law does allow that experience to come through structure: representing a non-resident that holds it, or being more than half owned by partners that each have two years. A new company with no such link does not meet the condition.

How long does the process take?

Only one deadline is fixed in law: 10 days for the Revenue Service to review the application. After that it moves to the Ministry of Finance and then to the Government, and no deadline is set for those stages. Plan in months rather than weeks, and do not tie a launch date to it.

Is the status lost if the company earns non qualifying income?

Yes, if that income exceeds 2% of the income from permitted activities excluding VAT. The status terminates once the company no longer meets the conditions. Any side revenue, including rent and one off services outside the list, needs to be counted in advance.

Does the regime work for a sole trader?

No. The conditions are written for an enterprise and refer to shares, partner enterprises and representation of a non-resident. A sole trader does not fit that structure. Sole traders in Georgia use other regimes, primarily small business status at 1% of turnover.

Do I need staff in Georgia?

In practice yes. The ordinance requires the basic income generating activity to be carried out in Georgia, with adequate human resources of the necessary qualification and appropriate operating costs. No headcount is named, but a company with no people and no costs in the country does not satisfy the presence test.

How Legalese handles this

We test the company against the conditions before filing: we calculate the share of non qualifying income, map the actual activity onto the codes in the list, and assess whether the ownership structure carries the two year experience. That is cheaper than a government refusal followed by a second application.

We then assemble the document package, including proof of the non-resident's experience where the status is claimed through representation, and run the application through all three stages.

If the company is not registered yet, we start with LLC incorporation shaped around the future status, so the ownership structure does not have to be rebuilt later. Service details: international company status in Georgia.

Key points

• Rates: 5% profit, 5% on employment income, dividends untaxed at source, property tax exemption except land
• Two years of experience in the permitted activity is required, directly or through ownership structure
• Non qualifying income must stay within 2% of income from permitted activities
• Real presence is required: activity, qualified people and costs in Georgia
• The Government of Georgia decides, and the status runs indefinitely

To check whether your company meets the conditions, book a free consultation.