The 2026 amendments to Georgia’s Tax Code strengthen transfer pricing rules, extend exemptions and incentives for agriculture, real estate, small businesses, and cooperatives, introduce VAT relief for investment gold, and clarify dividend and profit distribution rules.
Georgia has issued Law No. 1061-IVМС-XIМП dated 12 November 2025 in the Official Gazette, introducing several amendments to the Georgian Tax Code. The amendments introduce targeted incentives for agriculture, capital markets, construction, and small-scale entrepreneurs, while revising rules for corporate taxation, transfer pricing reporting, and VAT compliance.
Transfer Pricing changes
Country-by-Country reporting (CbCR) requirement strengthened
The ultimate parent entity of a multinational enterprise group that is a Georgian tax resident must now submit a CbC report within 12 months after the end of the reporting year. This aligns Georgia more closely with OECD BEPS standards and raises compliance expectations for large groups.
Distribution of profits and dividend rules updated
New provisions clarify that certain dividends received and subsequently distributed by resident enterprises will be exempt from withholding tax and from inclusion in taxable income.
Personal tax measures and entrepreneur incentives
Relief for agricultural income extended to 2028
Several provisions exempt income and employment-related payments arising from agricultural activities, including activities carried out through agrarian cooperatives, provided that the annual income does not exceed GEL 200,000. These exemptions cover tax-free agricultural income, interest earned on qualifying corporate debt instruments, and salary payments made in connection with eligible agrarian operations.
Micro-business and small business reforms
Micro-businesses must now file annual tax declarations by 1 April.
VAT and customs changes
Agricultural, real estate, and cooperative activities receive broad VAT relief.
Until 1 January 2028, key exemptions include the supply of agricultural products and related services within cooperatives, the import of raw tobacco, VAT relief for qualifying real estate and construction activities, and simplified VAT treatment for specific hiring, leasing, and property transactions.
A significant update extends the real estate VAT exemption to projects with construction permits issued both before and after the 2008 reforms. Eligible projects remain VAT-exempt until 1 January 2029, with specific provisions for assessing project completion, determining building eligibility, and applying limitation periods, which are now adjusted according to the year of the transaction.
VAT exemption for Import and supply of investment gold
A VAT exemption has been introduced for the supply and import of investment-grade gold, applying to gold bars with a minimum fineness of 995/1000 and gold coins with a minimum fineness of 900/1000.
Capital market and debt instruments relief
Interest earned on publicly offered and exchange-listed debt securities issued by a Georgian resident, whether by residents or non-residents, is exempt from tax until 1 January 2028.
Suspension and extension of existing rules
Selected VAT and excise rules are suspended until 2028. Several statutes provide extended limitation periods based on the year of the underlying exempt transaction, with some extending up to 14 years for historical transactions.
Other notable sector-wise tax incentives
Special tax benefits have been extended or clarified for agricultural cooperatives, real estate developers, small-scale market vendors, short-term rental providers, and insurance companies regarding the treatment of profit distributions.
The changes take effect from 1 January 2026, with many temporary relief measures extended until 1 January 2028.
