Summary
The figures
50+
Ministry of Finance of Georgia·1 Oct 2026
5%
Tax Code of Georgia, Art. 130–131, 134·1 Oct 2026
As written
1 provision
Sets the withholding rates on income paid to non-residents from a Georgian source, including dividends, interest, royalties and service fees. (Paraphrased.)Tax Code of Georgia, Article 134 (taxation of non-residents at source)
How it works
Georgia's domestic withholding rates are already low, so a treaty matters most where it takes a rate to zero, where the investor's home country taxes foreign dividends, or where the investor needs certainty on permanent establishment and capital gains. The treaties largely follow the OECD model.
To claim a treaty rate, the Georgian payer needs the recipient's certificate of tax residence from its home authority and files with the Revenue Service for the reduced rate, or the recipient claims a refund afterwards. Without the certificate the domestic rate applies.
There is no treaty with the United States. US investors rely on domestic rates and on foreign tax credits at home. Structures through the UAE, the Netherlands or Cyprus are common for that reason; each has its own substance tests.
FAQ
Questions investors ask about this rule
Which countries have treaties with Georgia?
Most EU members, the UK, Switzerland, Israel, the UAE, Türkiye, China, India, Japan, Singapore, Qatar, Saudi Arabia and others. The Ministry of Finance publishes the current list; we check it on every review of this page.
Does a treaty reduce the 15% corporate tax on distributions?
No. That tax is on the Georgian company. Treaties reduce the withholding on the dividend the recipient receives.
How do I prove I am tax resident in Georgia?
Apply to the Revenue Service for a certificate of tax residence, based on 183 days of presence or on the high-net-worth election.
Sources
Sources
- Ministry of Finance of Georgia, treaty list
- Tax Code of Georgia (matsne.gov.ge), current text
- Revenue Service of Georgia, residence certificates