International tax advisory is a high-level legal service essential for companies and individuals operating across multiple jurisdictions. In the era of globalization, businesses increasingly face cross-border tax challenges. This includes structural planning, transfer pricing, Controlled Foreign Company (CFC) rules, and the interpretation of international tax treaties. Georgia, as a regional hub, offers an attractive tax environment, but international transactions require careful analysis to ensure compliance with BEPS (Base Erosion and Profit Shifting) standards and to avoid double taxation. Incorrect structuring can lead to severe financial penalties and reputational damage. Our platform gives you access to experts with years of experience in international tax law.
The service covers all critical aspects of international taxation:
- Cross-Border Transaction Structuring: Creating optimal corporate structures (holdings, subsidiaries) to achieve tax efficiency.
- Transfer Pricing: Analyzing prices of transactions between related parties and preparing documentation in accordance with OECD guidelines and Georgian legislation.
- Avoidance of Double Taxation: Utilizing DTTs to reduce taxation on dividends, interest, and royalties.
- Tax Residency Conflicts: Resolving cases where two or more countries claim an individual as a resident (Tie-breaker rules).
- CFC (Controlled Foreign Company) Risk Analysis: Issues related to taxing the profits of foreign subsidiaries in the founder's country of residence.
- Implementation of BEPS and MLI Instruments: Ensuring compliance with international standards.
International tax advisory is necessary in various scenarios. For example, a Georgian company plans to expand into Europe and wants to know where it is best to open a trading branch from a tax perspective. In another case, an international group enters Georgia and needs to structure financing (debt vs. equity) so that interest repatriation is tax-efficient. Also, a foreign investor buying real estate in Georgia for commercial purposes needs advice on taxes regarding profit repatriation. Regarding transfer pricing, a multinational company needs to justify that a service agreement with its Georgian subsidiary complies with arm's length principles.
The legal framework relies on the Tax Code of Georgia (especially chapters on international taxation and transfer pricing), as well as International Treaties on the Avoidance of Double Taxation. Important is the Order of the Minister of Finance of Georgia "On the Assessment of International Controlled Operations," which regulates transfer pricing. Additionally, experts are guided by the OECD (Organisation for Economic Co-operation and Development) Model Tax Convention and commentaries used to interpret international treaties.
The process begins with a study of the client's global structure and business model. The consultant conducts a diagnostic (Tax Health Check) to identify potential risks. In the case of transfer pricing, a comparability analysis (Benchmarking study) is prepared. In structuring projects, the specialist prepares a memorandum describing the step-by-step plan and expected tax effects in each jurisdiction. The final stage involves implementing recommendations and, if necessary, obtaining an Advance Tax Ruling from the tax authority.
Legal.ge is a platform connecting you with highly qualified tax lawyers. International taxation is not a field where mistakes are permissible. Our specialists are constantly updated on global tax trends and can offer solutions that protect your business and increase its efficiency. Find your strategic tax partner on Legal.ge.
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