The purpose of Article 165²
Article 165² of the Code of Administrative Offences of Georgia establishes administrative liability for evading the subsoil use tax. The norm is an administrative-law instrument protecting the fiscal interest of the state in the sphere of the rational and tax-burdened use of subsoil resources.
Subsoil use is an activity carried out under a special permit, and its coverage by the tax is a significant source of the state budget. Evading the tax means that the use actually takes place but the tax is not paid or is not paid in full — the legislature responds to this with an administrative sanction.

