British Business and Persons in Georgia
The taxation of companies, natural persons and investors who have moved from the United Kingdom to Georgia rests on the general foundations of the Georgian Tax Code, and its two central rules operate as for everyone else: the 183-day residency test and the credit of tax paid abroad. For the British side the calculation of precisely these two is especially topical: mobile professionals and managers from the United Kingdom often travel abroad, and accurate record-keeping of days of presence is the foundation of every decision.
Determining Residency and Counting Days
Article 34 of the Tax Code provides that a natural person is considered a resident of Georgia for the whole current tax year if he or she actually stays on the territory of Georgia for 183 days or more in any continuous 12-month period ending in that tax year. The time during which the person left Georgia specifically for medical treatment, rest, business travel or study also counts as presence. Not counted is the time of diplomatic-consular persons and their families, employees of international organizations, transit, and medical or holiday stays. Every day counts as a day of presence regardless of duration; status is determined separately for each tax period, and days counted in a previous period are not counted again. For a British person it is also relevant that where residency in no country is established, upon application to the tax authority a citizen of Georgia is deemed a resident — while a foreign citizen may be granted residency under the procedure established by the Minister of Finance.
The Credit and Treaty Relief
The link between profit paid by a British company in Georgia and tax paid in the United Kingdom is created by Article 124: an enterprise is entitled to credit profit tax paid outside Georgia for the corresponding year, by income from a non-Georgian source, up to the cap of what would have been charged in Georgia. For a non-resident, the use of treaty-based relief and the refund of tax paid in Georgia follow Article 125 and the procedure established by the Minister of Finance's order — at this stage documentary substantiation of residency and of payment abroad is decisive. A properly prepared package returns the overpaid tax; an incorrect one leads the claim to rejection.
What the British Side Should Plan
Three practical steps of planning: first — monitoring days of presence before the residency decision, not after; second — structuring income sources so that the object and cap of the credit are known in advance; third — proactive preparation of documentation so that a relief claim is possible at the moment of payment and not years later. An accounting team working to British standards is a partner in this process, and early acquaintance with Georgian requirements lightens its work.
Additional Grounds of Residency and Practical Details
The 183-day test is the principal but not the only route to residency. By law, residency may also be granted to a person supported by significant property — a person defined by the Law on the Securities Market — under the procedure and conditions determined by the Minister of Finance. Moreover, where a natural person's residency in any country is not established, upon application to the tax authority the person is deemed a resident of Georgia if he or she is a citizen of Georgia; residency may likewise be granted to a foreign citizen in cases and by the procedure determined by the minister. The practical details matter too: resident or non-resident status is determined separately for each tax period, and the days by which the person was counted as a resident in a previous period are not reconsidered in the next — multi-year planning without a registry of days is therefore impossible. Remember also: time spent abroad on business travel or study counts as presence even when the person is not physically in Georgia — this rule is often surprising, and precise record-keeping is critical precisely because of it.
Frequently Asked Questions
How is residency determined for a British person?
By the same 183-day test as for everyone: 183 days or more of presence in any continuous 12-month period ending in the current tax year.
Is tax paid in the UK credited?
Yes, under Article 124 — as profit tax, on non-Georgian-source income, up to the cap of the Georgian tax.
How do I claim treaty relief?
Under the procedure of Article 125, established by the Minister of Finance's order — with a complete documentary package.
Which days are not counted?
Diplomatic-consular presence, transit and medical or holiday time abroad; leaving Georgia for treatment, on the contrary, counts.
How We Help on Legal.ge
On Legal.ge we assist with all matters of Georgia-UK taxation: residency computation with a registry of days, determination of the credit object, and preparation of relief and refund claims. Contact us when planning the move — a correct structure in the first year shapes every subsequent one.