Profit tax
The Tax Code provides a 5% profit-tax rate for an International Company, applied within Georgia’s distributed-profit model and the regime’s specific calculation rules.
International Company status · Georgia 2026
A 5% regime.
With real entry conditions.
A decision guide for qualifying Georgian IT and maritime-service enterprises considering International Company status, its tax effects, application evidence and ongoing restrictions.
Employment income
Qualifying employment income paid by the International Company is taxed at 5%, with reporting under the tax-administration procedure.
Dividends
Dividends issued by an International Company are not taxed at source and are excluded from the recipient’s gross income under Article 23.
Property
Qualifying property used for permitted activity can be exempt from property tax other than land; mixed or non-qualifying use needs careful review.
Controlled workflow
From facts
to a defensible result.
Screen the enterprise
Confirm Georgian entity type/tax model, ownership/group history, actual qualifying IT or maritime services, customers, delivery location, staff and non-permitted revenue.
Map activity to Ordinance No. 619
Do not rely on broad words such as software, consulting or shipping. Match contracts, invoices, staff functions and deliverables to the permitted list.
Build the evidence file
Prepare corporate/group documents, experience and activity evidence, contracts, staff/subcontractor facts, financial history and a clear description of how services are produced and supplied.
Apply through the prescribed route
The enterprise applies through the Revenue Service process; the status is granted by the Government of Georgia. No adviser can guarantee approval or timing.
Operate inside the status
Monitor permitted revenue, ancillary activity, staffing, related-party pricing, expenses, property use, payroll and changes in contracts or business model.
Points that change the answer
Do not let the headline replace the analysis.
Not Virtual Zone
Virtual Zone Person and International Company are different regimes with different statutory mechanics, eligibility and maintenance. Do not market them as two names for the same exemption.
Permitted activity matters continuously
Starting an unpermitted economic activity can cause loss of status from the beginning of the relevant calendar year under the Tax Code.
Substance must match documents
Contracts, invoices, people, systems and delivery evidence should tell the same operational story. A copied activity description is not sufficient.
Related parties
Cross-border group charges, IP, management services and cost allocations may require transfer-pricing and withholding/VAT analysis.
5% is not “all taxes”
Payroll, VAT, reverse-charge VAT, withholding, import, land/property, reporting and foreign-country tax consequences must be tested separately.
Foreign-country exposure remains
The Georgian status does not prevent a permanent establishment, payroll, management/control or controlled-company issue elsewhere.
Professional support
International Company eligibility and application support
Activity-to-ordinance mapping, corporate and experience evidence checklist, contract/revenue review, application narrative and filing coordination. Restructuring, transfer pricing, foreign opinions, accounting reconstruction and ongoing compliance are separate.
Connected decisions
Continue with the operating framework.
Primary sources and related guidesTax Code of Georgia · Article 23 ↗Revenue Service · International Company service ↗Tax-administration rules for International Companies ↗Virtual Zone comparison guide →
Last reviewed 17 July 2026. General information only, not an opinion for a specific taxpayer. Rates, procedures, treaties and administrative practice can change. A written engagement must define the facts, jurisdictions, assumptions and scope.