A late tax declaration gives rise to two distinct sanctions: a fine, calculated as a percentage of the tax chargeable on the declaration, and a surcharge, a daily percentage on the unpaid amount. The Georgian Tax Code sets out precisely the conditions, caps and deadlines for both, and the same Code establishes the full dispute-resolution mechanism — from the Revenue Service to the Dispute Resolution Board at the Ministry of Finance, and then to the court. On this page we explain how the fine and the surcharge are computed, which legal arguments can reduce an assessment, and within which deadlines the appeal route operates. One clarification up front: reduction here means legal argumentation before the dispute-resolution bodies — outside the paths established by law, the Code provides no mechanism for "waiving" these sanctions.
The Fine for a Late Declaration — 5 and 10 Percent
A breach of the deadline for submitting a declaration/report to the tax authority, where the period of delay does not exceed 2 months, leads to a fine of 5 percent of the amount of tax chargeable on that declaration; and where the delay exceeds 2 months — 10 percent. The key words are "tax chargeable on that declaration": the fine is computed not from turnover but from the tax chargeable under the specific declaration, and if the amount chargeable on the declaration equals zero, no fine is imposed on the person at all.
Here lies the trap many taxpayers have fallen into: if a person fails to submit a declaration, the law deems that person to have submitted a declaration on which the chargeable tax equals zero. It may seem no fine is due — but a declaration submitted later for the same reporting period is treated as submitted late, and once the real tax emerges, the fine is charged precisely on that amount. Note also that the declaration is computed in whole lari and an obligation below 1 lari is zeroed — a detail that belongs in the computation.