--- title: "Tax Planning for Expats" url: "https://legal.ge/en/service/migration-and-immigration-law-en/tax-planning-for-expats-en" field: "Migration & Immigration Law" description: "Expat tax planning in Georgia: the 183-day residency rule, source-taxation rates, exemptions and the permanent establishment threshold. Legal.ge." reviewed: "2026-06-27" updated: "2026-10-14" publisher: "legal.ge" --- # Tax Planning for Expats > Source: legal.ge, https://legal.ge/en/service/migration-and-immigration-law-en/tax-planning-for-expats-en 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. ### What is the residency threshold? 183 days or more in any continuous 12-month period ending in the tax year. ### How is a non-resident's income taxed? At source: royalty 5 percent, telecom/transport and other amounts 10 percent; a recalculation request may be filed by 1 April. ### Which gains are exempt? The sale of a dwelling owned for more than 2 years and of a vehicle registered more than 6 months ago. ### What creates a permanent establishment? An office, branch or construction site, or management of the enterprise by another person for more than 3 months; mere ownership does not.