Expat tax planning in Georgia rests on four questions: who counts as a resident and how days are counted, how a non-resident's income is taxed at source, which incomes are exempt, and when activity creates a permanent establishment. This page explains these four pillars on the basis of the Georgian Tax Code — the norms that govern every planning decision. We note in advance: the tax regimes of other states — including the United States models or the rules of the Schengen area — are not applicable in Georgia; only the Georgian Code operates here.
The starting point of planning — the residency rule
A natural person is treated as a resident of Georgia for the entire current tax year if he or she is actually present on the territory of Georgia for 183 days or more in any continuous 12-month period ending in that tax year. The day-counting rules matter just as much: time actually present includes time during which the person was in Georgia, as well as time during which the person went abroad specifically for medical treatment, rest, a business trip or study. At the same time, the following do not count as actual presence: time in Georgia under diplomatic or consular status, as an employee of an international organisation, in transit from one foreign country to another, or specifically for medical treatment or rest. A day of presence counts regardless of how long the person stayed that day. The status is determined separately for each tax period, and days counted in a previous period are not reconsidered in the next one.
Taxation of a non-resident's income at source
A non-resident's income from a source in Georgia that is not attributable to a permanent establishment is taxed at source without deductions. The rates are: royalty — 5 percent; amounts paid for international telecommunications and international transport services — 10 percent; income of non-resident sub-contractors in oil and gas operations — 4 percent; other amounts from a Georgian source — 10 percent; certain income of a person registered in a preferential-tax jurisdiction — 15 percent. Dividends and interest are taxed under their own norms, while salary and rental services follow the respective rate rules. Recalculation is an important option: a non-resident may file a declaration by 1 April of the year following the reporting year requesting the recalculation and refund of the withheld tax — in that case income is determined as the difference between aggregate income and deductible amounts.
Which incomes are exempt
The Code exempts a significant share of natural persons' incomes from personal income tax. The most relevant for expats are: income of a non-resident from employment in foreign diplomatic and equated missions in Georgia; grants and state pensions; contributions of up to 6 000 GEL per year to a voluntary private pension scheme; alimony; the value of property received on divorce; the gain from the sale of a dwelling owned for more than 2 years and of assets owned for more than 2 years, as well as of a vehicle registered more than 6 months ago; property received by gift or inheritance by first- and second-line heirs, and up to 150 000 GEL per year for third- and fourth-line heirs; other gifts up to 1000 GEL per year. We separately note the agricultural segment: until 1 January 2028, the taxable income of a person employed in agricultural production from the first supply of products produced in Georgia is exempt if the aggregate annual income from such supply does not exceed 200 000 GEL.
Permanent establishment — the threshold in Georgian taxation
A permanent establishment of a foreign enterprise or a non-resident natural person is a defined place through which that person carries on economic activity in Georgia wholly or in part. Equated to it are a construction site, an installation object, a place of management, a branch, a representative office, an office, an agency, a mine. An additional rule exists: management of the enterprise by another person for more than 3 months is also treated as a permanent establishment. At the same time, the activity of an independent professional intermediary, agent or broker does not create one; nor does mere ownership of securities or property, mere secondment of employees, or preparatory and auxiliary activity — for example storage, display, purchasing or information gathering. The registration obligation lies with the tax authority, which also maintains the relevant register. In planning this threshold is decisive: beyond it, income moves from source taxation into the full tax-accounting regime.
Frequently asked questions
Below we answer the most common questions about expat tax planning.
How many days does it take to become a resident?
183 days or more in any continuous 12-month period ending in the current tax year; a day of presence counts regardless of its duration.
How is my income taxed as a non-resident?
At source, without deductions — for example, royalty at 5 percent, telecommunications and transport at 10 percent, other Georgian-source amounts at 10 percent; a refund request may be filed by 1 April.
Is the gain on selling my apartment taxed?
No, if the dwelling was owned for more than 2 years; for a vehicle, more than 6 months from registration is sufficient.
When do I become taxed through a permanent establishment?
When the activity rests on a defined place — an office, branch, construction site — or another person manages the enterprise for more than 3 months; mere ownership or preparatory activity does not have that effect.
How We Help on Legal.ge
The Legal.ge team helps expats plan their tax status: we count residency days, assess the effect of source taxation, determine the availability of exemptions and the risks of a permanent establishment. In a written consultation you receive a conclusion built on your calendar and income structure. Contact us through the Legal.ge website.