Tax Treaties in Georgia
The Number of Tax Treaties indicator measures the breadth of a country's double taxation agreement (DTA) network. Georgia scores 48/100 with approximately 57 active double tax treaties. The network covers most of Georgia's significant trading and investment partners, though notable gaps remain compared to major financial center jurisdictions.
What the 57 Treaties Cover
Georgia's DTA network was built primarily after independence (1991) and has expanded steadily, with particular growth in the 2000s–2010s under reform-era governments. The treaties follow the OECD Model Convention framework and cover:
- EU Member States: Germany, France, Netherlands, Austria, Poland, Czech Republic, Hungary, Romania, Bulgaria, Croatia, Estonia, Latvia, Lithuania, Greece, Spain, Italy, Belgium, Luxembourg, Sweden, Denmark, Finland
- Other European states: United Kingdom, Switzerland, Norway, Ukraine, Belarus, Serbia, North Macedonia, Albania, Armenia, Azerbaijan
- Asia/Pacific: China, South Korea, Japan, India, Turkey
- Middle East: UAE, Kuwait, Bahrain, Iran
- CIS: Russia (technically still in force), Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, Uzbekistan
What DTAs Actually Do for Georgia
Double tax treaties prevent the same income from being taxed in both the source country and the residence country. For Georgian-resident businesses and individuals, DTAs are practically relevant in several ways:
- Reduced withholding taxes: Dividends from German, Dutch, or UK subsidiaries flow to Georgian holding companies with reduced withholding (typically 5–10% under treaty vs. statutory rates of 15–25%).
- Royalty and interest flows: IP-owning structures in Georgia benefit from 0% withholding on royalties under certain treaties.
- Employment income protection: Expatriate employees seconded to Georgia can invoke the treaty to avoid double taxation in their home country.
- Permanent establishment rules: DTAs clarify when a Georgian company's activities abroad create taxable presence – important for businesses with sales or distribution operations in treaty countries.
Gaps and Limitations
The most notable missing treaty is with the United States. Georgia and the US have only a FATCA intergovernmental agreement (for financial account reporting), not a full income tax treaty. American citizens and green card holders residing in Georgia therefore face the full US worldwide taxation system without treaty protection – potentially creating double taxation on Georgian-source income. Similarly, Australia and Brazil are not covered. For Canadians, a treaty does exist.
Georgia's OECD Multilateral Instrument (MLI) participation means that many older bilateral treaties have been updated to include BEPS (Base Erosion and Profit Shifting) anti-avoidance provisions, making aggressive treaty shopping strategies less viable.
FATCA and CRS: Information Exchange
Georgia participates in the OECD Common Reporting Standard (CRS) for automatic exchange of financial account information. This means Georgian banks report account information on foreign residents to their home tax authorities, and foreign banks reciprocally report on Georgian residents' foreign accounts. The era of using Georgia as a banking secrecy location is effectively over. Legitimate tax planning based on Georgia's favorable rates and regimes remains fully viable; undeclared offshore structures do not.
Conclusion: Score 48/100 – Georgia's 57 DTAs provide adequate protection for the vast majority of European-focused investors and entrepreneurs. The lack of a US treaty is a meaningful gap for American citizens. The network is functional, well-maintained, and sufficient for most practical international tax planning scenarios centered on the European and CIS markets.
This article was created on April 14, 2026
