The Two Tax Axes of the Export Model
A live-dealer studio serving foreign operators rests, in Georgian tax law, on two axes: the object of profit taxation and the operations taxable with VAT. Article 97 of the Tax Code of Georgia provides: the object of taxation with profit tax for a resident enterprise is distributed profit; an expense or other payment not connected with economic activity; the gratuitous supply of goods/provision of services and/or transfer of funds; and representative expenses above the established limit.
In studio practice this list creates three sources of risk: planning the distribution of dividends within the parent group, controlling the deductibility of intercompany payments, and the fact that gratuitous service — for example, demonstration sessions for a partner — becomes an object of taxation. Therefore contractual discipline, where every service is substantiated and priced, is the precondition of a clean tax base.