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Rules and tax · as written

Reinvested profit: 0% until distribution

Since 1 January 2017 a Georgian company pays no corporate income tax on profit it keeps or reinvests. The 15% tax falls only when profit is distributed, computed on the grossed-up amount (distribution × 15/85). Dividends paid to individuals and non-residents carry a further 5% withholding, before treaty relief.

Last updateNext update9 Oct 2026~9 Nov 2026Checked against the current text of the Tax Code and Revenue Service guidance.
Nikusha PruidzeFounder · 1 min read · 2 sources

Summary

The figures

0%

No corporate income tax is charged on retained or reinvested profit of a Georgian resident company.

Tax Code of Georgia, Art. 97·1 Oct 2026

15%

Corporate income tax is due when profit is distributed, on the grossed-up amount: distribution × 15/85.

Tax Code of Georgia, Art. 97–98·1 Oct 2026

5%

Withholding on dividends paid to individuals and to non-resident companies, before any treaty reduction.

Tax Code of Georgia, Art. 130·1 Oct 2026

As written
1 provision

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)

How it works

The regime, often called the Estonian model, applies to Georgian resident companies and to permanent establishments of foreign companies. Banks, insurers, microfinance organisations and a few other regulated entities moved to it later and on their own schedule, so check the date if you are in financial services.

Tax is triggered by a distribution or by a deemed distribution. Deemed distributions include expenses with no business purpose, gifts and free supplies, representation costs above the limit, and certain payments to related parties and to persons in low-tax jurisdictions. Loans to shareholders can be treated as distributions; ask before lending retained profit to an owner.

The return is monthly and is filed only for months with a taxable event, by the 15th of the following month. A company that reinvests everything files nothing and pays nothing on profit, year after year.

How it combines with the special regimes

International Company status replaces the 15% with 5%. Virtual Zone status exempts the profit from exported IT services entirely. A free industrial zone company pays no profit tax at all on zone activity. Each of those regimes has its own page.

Worked example

A company earns $1,000,000 in 2026 and pays $300,000 out as dividends. Corporate income tax: $300,000 × 15/85 = $52,941. Dividend withholding: 5% of $300,000 = $15,000, less under a treaty. Total tax on the distribution: $67,941, or 22.6% of the cash paid out. The $700,000 kept in the business carries no tax until the day it is distributed.

FAQ

Questions investors ask about this rule

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.

Sources

Next step

Not legal advice, by design. For your case, we work with your lawyer or introduce one we have checked.

Tell us the structure and the sector. We reply within one working day with the regime that applies and what to verify first.

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