Taxing the American Side Under Internal Rules
The taxation of American natural persons and companies in Georgia proceeds under the internal rules of the Georgian Tax Code: no US-Georgia double taxation agreement exists, so treaty-based relief cannot be planned — planning rests entirely on internal norms. These conditions leave two principal instruments: the 183-day residency test and the credit of tax paid abroad. The right approach produces an outcome similar to what a treaty regime gives with other countries — though by an entirely different route.
The 183-Day Test and Day Records
Under Article 34, a natural person is considered a resident of Georgia for the whole current tax year who actually stays on the territory of Georgia for 183 days or more in any continuous 12-month period ending in that tax year. For professionals moving from the US to Georgia and remote workers this is the decisive parameter. Time spent abroad specifically for medical treatment, rest, business travel or study also counts as presence; the time of diplomatic-consular persons and international organizations' staff, transit and medical or holiday stays abroad does not. Every day counts regardless of duration; status is determined separately for each tax period, and days counted in a previous period are not counted again.
The Credit — the Principal Instrument
In the absence of a treaty, Article 124 is especially important: an enterprise is entitled to credit profit tax paid outside Georgia, for the corresponding tax year, against the tax paid in Georgia on that profit, with respect to income not received from a Georgian source. Thus profit tax paid in the US is credited against Georgian tax — and this credit rests precisely on an internal norm, not on a treaty. The cap still operates: the credited amount must not exceed the tax that would have been charged on that profit in Georgia under Georgian rules and rates. The relief mechanism of Article 125 concerns only treaty-based benefits — in the absence of an agreement with the US this route does not work, and it is precisely for this reason that all planning is shifted onto the credit and structure.