Intra-Group Reporting and Transfer Pricing in Gambling Holdings

What is the key criterion of related persons?

Direct or indirect participation in management, control or capital — including ownership of more than 50 percent or practical control over entrepreneurial decisions; any transaction between such persons is controlled.

What does the arm’s length principle mean?

Transaction conditions must not differ from those independent enterprises would have agreed in a comparable situation; otherwise the profit that would have arisen may be included in the taxable base.

Should documentation be prepared before a request arrives?

The explanation is submitted upon the tax authority’s request, but in practice it is convincing only when backed by a prepared analysis — this is exactly what intra-group reporting is for.

Does the regime cover deals with residents of preferential-tax countries?

Yes, the adjustment rules extend to transactions with residents of preferential-tax countries regardless of relatedness, and such transactions are treated as controlled.

6 min·22 Sep 2026

Why Transfer Pricing Is a Core Issue for Gambling Holdings

A gambling business typically operates through a holding structure: one company holds the permit, another provides the technology platform, a third runs marketing, and a fourth manages the retail network of cash desks. Between these companies, contracts for services, licences, broadcasting rights and brand use are concluded daily, and it is precisely these intra-group transactions that the transfer pricing regime of Articles 126, 127, 128 and 129 of the Georgian Tax Code targets. Where the price between group companies differs from the price independent parties would have agreed, the tax authority gains a lawful basis to adjust taxable profit. For a gambling holding, whose margins attract heightened attention, this is not a theoretical risk but a standing compliance agenda.

This page explains how the concept of related persons is determined, what the arm’s length principle requires, which methods exist for pricing international controlled transactions, and how documentation should be organised so that the group can present a justification when the authority issues a request.

Intra-Group Reporting and Transfer Pricing in Gambling Holdings

What is the key criterion of related persons?

What does the arm’s length principle mean?

Transaction conditions must not differ from those independent enterprises would have agreed in a comparable situation; otherwise the profit that would have arisen may be included in the taxable base.

Should documentation be prepared before a request arrives?

The explanation is submitted upon the tax authority’s request, but in practice it is convincing only when backed by a prepared analysis — this is exactly what intra-group reporting is for.

Does the regime cover deals with residents of preferential-tax countries?

Yes, the adjustment rules extend to transactions with residents of preferential-tax countries regardless of relatedness, and such transactions are treated as controlled.

6 min·22 Sep 2026

Why Transfer Pricing Is a Core Issue for Gambling Holdings