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Tbilisi, Georgia

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  1. Services
  2. Tax Law
  3. International Tax
  4. Cross-Border Tax
  5. Tax Treaty Application

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Cross-Border Tax

Tax Treaty Application

What does Article 124 regulate?

The credit of profit tax paid abroad against Georgian tax — on non-Georgian-source income and up to the Georgian tax cap.

What does Article 125 regulate?

A non-resident's use of treaty-based relief and the refund of tax paid in Georgia — by the Minister of Finance's order.

What is the credit cap?

The credited amount does not exceed the tax that would have been charged in Georgia on the same profit.

What documentation is needed?

Proof of payment abroad and residency documentation — the detailed list is in the minister's order.

4 min·8 Feb 2026

How a Double Taxation Treaty Works in Georgia

A double taxation agreement determines which state taxes which income and which concedes. But the treaty's text alone is not enough: the Georgian Tax Code for its part establishes how the agreement is applied in relation to Georgian taxes. Two principal mechanisms of application exist: the credit of tax paid abroad and the use of treaty-based relief by a non-resident.

Updated: 23 Oct 2026

Verified against current law: 27 Jun 2026

Legal basis:

  • საქართველოს საგადასახადო კოდექსი