Кратко
Показатели
0%
Tax Code of Georgia, Art. 97·1 окт. 2026 г.
15%
Tax Code of Georgia, Art. 97–98·1 окт. 2026 г.
5%
Tax Code of Georgia, Art. 130·1 окт. 2026 г.
По тексту закона
1 положение
For a resident enterprise the object of taxation is distributed profit; expenses or other payments not related to economic activity; free-of-charge supplies of goods, services or money; and representation expenses above the statutory limit. (Paraphrased; the article text on matsne.gov.ge governs.)Tax Code of Georgia, Article 97 (object of profit taxation)
Вопросы и ответы
Вопросы инвесторов об этом правиле
Does this apply to a branch of a foreign company?
Yes. A permanent establishment in Georgia is taxed on the same basis: profit attributed to it is taxed when it is distributed or deemed distributed to the head office.
What counts as a distribution?
Dividends in cash or in kind, and anything the Tax Code treats as equivalent: non-business expenses, free supplies, over-limit representation costs and certain related-party payments. The article is short; read it before paying anything to an owner.
Can a company lend its retained profit to a shareholder?
It can, but some loans to shareholders and related parties are treated as distributions and taxed. Structure the loan with your accountant before it is paid.
Is the 15% reduced by a tax treaty?
No. Treaties reduce the 5% dividend withholding, not the 15% corporate tax, which is a tax on the company rather than on the recipient.
Источники
Источники
- Tax Code of Georgia (matsne.gov.ge), current text
- Revenue Service of Georgia, guidance