Foreign Direct Investment (FDI) in Georgia

Foreign Direct Investment

Does shareholding create an establishment?

No — owning Georgian shares or units creates no tax presence.

What is the dividend tax?

5 percent of the payable amount at source, with treaty relief in mind.

How is a share exit taxed?

Outside an establishment — on the difference between aggregate annual income and deductions.

How does treaty relief work?

The treaty removes or limits the source rate; application begins with residence determination.

Can withheld source tax be recovered?

Yes — by a declaration submitted until 1 April of the following year, demanding recalculation and refund.

4 min·9 Jan 2026

Foreign Direct Investment — the Georgian Tax Interface

Georgia's investment regime is open: there is no law imposing special screening or capital requirements on foreign investors, and what actually governs a foreign investor is the interface of the Tax Code: the denial of a permanent establishment for mere shareholding, taxation only through an establishment or at source, the 5 percent dividend withholding rate, source rates and treaty relief. The state-treaty layer is treated on another page; here the carrier is the Tax Code. Note also that foreign investment-treaty frameworks are not Georgian domestic law — the page is carried by Georgia's open-entry, tax-interface regime.