Mining in Tax Law — Enterprise and Taxpayer
Planning crypto mining in Georgia begins with two foundational constructions of the Tax Code. The first is the enterprise: the Code treats as an enterprise formations carrying out economic activity or created for that purpose — legal entities created under Georgian legislation, foreign formations and their permanent establishments, and associations. The second is the taxpayer: profit tax is paid by a resident enterprise, and by a non-resident enterprise that carries on activity in Georgia through a permanent establishment and/or derives income from a Georgian source. The choice of form — a group member company, a local legal entity or the permanent establishment of a foreign structure — therefore directly determines who accounts for profit tax and how.
Setting up a mining operation also entails registration of the enterprise and proper bookkeeping: the accounts are kept under the procedure established by the Tax Code, with the detailed requirements set out in the corresponding normative acts. The purchase of hardware, the cost of electricity and the cryptocurrency received must be distinguished from one another in the accounts — this separation is what makes the subsequent taxation transparent.