Georgia has introduced a new annual reporting obligation for international controlled transactions exceeding GEL 500,000, requiring detailed disclosure of related-party dealings, debt balances, and transfer pricing documentation, effective from the 2025 reporting period. 

RF Report

Georgia has issued Order No. 52 of 24 February 2026, in the Official Gazette, establishing a new annual obligation to report information on international controlled transactions.

The order introduces a mandatory reporting requirement for entities engaged in international controlled transactions that exceed a total value of GEL 500,000 per year.

When calculating this GEL 500,000 threshold, the following must be included:

  • The total monetary value of all international controlled transactions.
  • The market value of services or goods provided free of charge.
  • The volume of existing accounts payable and accounts receivable (debt).
  • This must be filled out as part of the tax declaration for the March reporting period, reflecting data from the previous calendar year.

The report requires disclosure of key details about related-party transactions, including the related party’s identity and residency, the nature of the relationship, and the type of transaction. It also covers the transaction amount in both the original currency and GEL, year-end debt balances, and the transaction start date. Additionally, taxpayers must indicate whether they hold transfer pricing documentation.

The order provides a practical example involving a loan from a Swiss parent company to illustrate how to accurately record currency conversions and interest expenses. These changes are designed to enhance transparency and apply to reporting periods starting from the year 2025.

Other key aspects of these new regulations are:

Definition of business restructuring

The decree provides a specific definition for business restructuring within this context. It refers to significant changes in commercial or financial relations between related parties that result in changes to the functions performed, risks assumed, or assets used. It also includes the termination, revision, or substantial modification of existing contracts.

Practical application (example)

In the example, a Georgian company and its 52% Swiss parent must report multiple loans under one credit line as a single entry. Interest is disclosed separately from the loan principal, and any outstanding balance at year-end must be reported, even if the loan was partially or fully repaid during the year.

This decree became effective immediately upon publication and applies to information submitted for the 2025 reporting period and onwards.