Summary
The figures
5%
Tax Code of Georgia, Art. 23; Government Decree 619·1 Oct 2026
5%
Tax Code of Georgia, Art. 23·1 Oct 2026
0%
Tax Code of Georgia, Art. 23·1 Oct 2026
As written
2 provisions
Status is granted by the Government to a Georgian enterprise carrying out permitted activities, with at least two years of experience in those activities, and may be revoked if the conditions cease to be met. (Paraphrased; the article and Decree 619 govern.)Tax Code of Georgia, Article 23 (International Company)
Lists the permitted information technology and maritime activities and the procedure for obtaining and losing the status.Government of Georgia, Decree No. 619 of 8 October 2020
How it works
The status is for companies that actually operate in Georgia: staff, premises and management here, serving clients mostly abroad. The permitted list covers software development and related IT services, and ship-management and other maritime services. The company, or shareholders holding a majority, must show at least two years of experience in those activities.
Three things make the regime valuable for a team based in Tbilisi. Salaries carry 5% personal income tax instead of 20%, which is a direct saving on the largest cost line. Distributed profit is taxed at 5% instead of 15%. And dividends leave the company with no withholding, which simplifies treaty planning.
Salary and research costs paid in Georgia can reduce the taxable distribution, and property used in the business is exempt from property tax other than land. Income from activities outside the permitted list is tolerated only within a small margin; beyond it the status is at risk.
Choosing between this and the Virtual Zone
Virtual Zone status gives 0% on exported IT profit but no salary relief and a strict substance test. International Company status suits a company with a real payroll in Georgia; Virtual Zone suits a lean exporter. Many groups run one of each.
Worked example
A software company with International Company status pays its twenty Tbilisi developers $1,200,000 a year. Personal income tax: 5%, or $60,000, instead of 20%, or $240,000. It distributes $500,000 of profit: corporate tax is 5% on the grossed-up amount, $500,000 × 5/95 = $26,316, and there is no dividend withholding. Total tax on payroll and distribution: $86,316, against $328,235 under the standard regime.
FAQ
Questions investors ask about this rule
How long does the status take?
The application goes through the Revenue Service to the Government. Allow one to two months from a complete file, longer if the experience evidence is thin.
Can a newly founded company qualify?
Yes, if its majority shareholders have at least two years of experience in the permitted activities, documented. A company with no track record and no experienced owners does not.
Does the 5% on salaries apply to foreign employees?
It applies to salaries paid by the International Company to employees working in Georgia, regardless of nationality. Remote staff abroad are a different question; check their own country's rules.
What revokes the status?
Income outside the permitted activities above the tolerated margin, loss of substance in Georgia, or a request by the company. Revocation can be retroactive for the period in breach.
Sources
Sources
- Tax Code of Georgia (matsne.gov.ge), current text
- Government Decree 619 (matsne.gov.ge), 8 Oct 2020
- Revenue Service of Georgia, guidance