Country-wide policy
International Company Status: 5% on Profit, 5% on the Salaries It Pays, and the Activity List Is the Government's
Article 23 of the Tax Code creates a status for a Georgian enterprise that carries on activities defined by an ordinance of the Government and earns income solely from them. The Government grants the status and the Government writes the list; the Code supplies only the consequences. Profit tax is 5% rather than the ordinary rate, income earned from working for hire at an international company is taxed at 5%, and a dividend it pays is not taxed at source and is not included in the recipient's gross income. The status cannot be held inside a Free Industrial Zone, and carrying on an activity outside the Government's list cancels it retroactively to 1 January of the year that activity began. The 5% on employment income is the part that matters to a person rather than a company, and it is the reason the residence permit for people employed in information technologies, in article 15 of the Law on the Legal Status of Aliens and Stateless Persons, names international companies by reference.
Topics it changes
What it requires
- A Georgian enterprise, not one established in a Free Industrial Zone
- Activities defined by an ordinance of the Government of Georgia, and income solely from them
- The status is granted by the Government of Georgia, not by the tax authority
At a glance
- Profit tax rate
- 5%
Article 23(10) of the Tax Code. The taxable amount is the payment made or cost incurred divided by 0.95, under article 23(11).
- Income from working for hire at an international company
- Taxed at 5%
Article 23(7) of the Tax Code, against the ordinary 20% in article 81(1).
- Dividends it pays
- Not taxed at source and not included in the recipient's gross income
Article 23(8) of the Tax Code.
- What cancels the status
- Carrying on an activity the Government's ordinance does not list
Article 23(3) of the Tax Code. Cancellation runs from 1 January of the year the activity began, so it is retrospective within that year.
What the law says
«1\. საერთაშორისო კომპანია არის საქართველოს საწარმო, რომელიც საქართველოს მთავრობის დადგენილებით განსაზღვრულ საქმიანობებს ახორციელებს და შემოსავალს მხოლოდ ამ საქმიანობებიდან იღებს. 2\. პირს საერთაშორისო კომპანიის სტატუსს ანიჭებს საქართველოს მთავრობა. 3\. საერთაშორისო კომპანიის მიერ ისეთი საქმიანობის განხორციელება, რომელიც საქართველოს მთავრობის დადგენილებით განსაზღვრული არ არის, იწვევს მისთვის საერთაშორისო კომპანიის სტატუსის გაუქმებას ამ საქმიანობის დაწყების წლის 1 იანვრიდან. 4\. საერთაშორისო კომპანია არ შეიძლება შეიქმნას თავისუფალ ინდუსტრიულ ზონაში.»Our translation - not official
1. An international company is a Georgian enterprise which carries out the activities determined by an ordinance of the Government of Georgia and receives income only from those activities. 2. The status of international company is granted to a person by the Government of Georgia. 3. The carrying out by an international company of an activity that is not determined by an ordinance of the Government of Georgia causes the cancellation of its international company status from 1 January of the year in which that activity began. 4. An international company may not be established in a Free Industrial Zone.
About this source
The official gazette and consolidated statute book of Georgia, a legal entity under public law under the Ministry of Justice. Every instrument lives at matsne.gov.ge/ka/document/view/<id>: laws, organic laws, Government resolutions, presidential decrees and ministerial orders, each page opening with a metadata block that gives the document number, the issuing body, the date of issue, the source and date of publication, the date of entry into force and the registration code, then listing every consolidated publication by date with its own publication index. Above the body of each page the site states which edition is being shown: კონსოლიდირებული ვერსია (საბოლოო) means the final consolidation, and a different line means it is not. Amending instruments are published separately and in full, each citing the registration code of the act it amends, so a schedule whose consolidation is paywalled can still be reconstructed from the original plus the amendments. Renders through Firecrawl without difficulty, including million-character statutes: the Georgian Tax Code comes back at 1,190,393 characters.
Standing: Maintains the text in force
Cannot be cited for: Three things it must not be cited for. First, it is not free for everything: for some Government resolutions - resolution No 255 of 5 June 2015 on visa-free entry, and resolution No 36 of 21 February 2013 on universal health care - the site serves only the text as originally published and prints დოკუმენტის კონსოლიდირებული ვარიანტის ნახვა ფასიანია, that viewing the consolidated version is a paid service requiring registration and the purchase of a viewing right. A reading of such a page is a reading of the original, however many consolidations have followed, and must be labelled as one. Second, it publishes the consolidated law and not the reasoning: no explanatory memorandum, no case law, no ministerial guidance, and a great deal of Georgian immigration and tax practice sits in orders of the Minister of Finance and the Minister of Internal Affairs which it holds but which are not linked from the parent act. Third, the Georgian pages are the law and the English pages at the matching address are not the same document - see ge-matsne-en. Pages render statutes inside HTML tables, so stored text carries table pipes and <br> markers around the publisher's own words.
We re-read it every 90 days. More about this source
«7\. საერთაშორისო კომპანიაში დაქირავებით მუშაობის შედეგად მიღებული შემოსავალი 5 პროცენტით იბეგრება. 8\. საერთაშორისო კომპანიის მიერ გაცემული დივიდენდი გადახდის წყაროსთან არ იბეგრება და დივიდენდის მიმღები პირის ერთობლივ შემოსავალში არ ჩაირთვება. 9\. საერთაშორისო კომპანიის მოგების გადასახადით დაბეგვრის ობიექტი ამ კოდექსის 97-ე მუხლის პირველი ნაწილის შესაბამისად განისაზღვრება. 10\. საერთაშორისო კომპანიის მოგების გადასახადის განაკვეთია 5 პროცენტი.»Our translation - not official
7. Income received as a result of working for hire at an international company is taxed at 5 per cent. 8. A dividend paid by an international company is not taxed at the source of payment and is not included in the gross income of the person receiving the dividend. 9. The object of profit taxation of an international company is determined under article 97(1) of this Code. 10. The profit tax rate of an international company is 5 per cent.
About this source
The official gazette and consolidated statute book of Georgia, a legal entity under public law under the Ministry of Justice. Every instrument lives at matsne.gov.ge/ka/document/view/<id>: laws, organic laws, Government resolutions, presidential decrees and ministerial orders, each page opening with a metadata block that gives the document number, the issuing body, the date of issue, the source and date of publication, the date of entry into force and the registration code, then listing every consolidated publication by date with its own publication index. Above the body of each page the site states which edition is being shown: კონსოლიდირებული ვერსია (საბოლოო) means the final consolidation, and a different line means it is not. Amending instruments are published separately and in full, each citing the registration code of the act it amends, so a schedule whose consolidation is paywalled can still be reconstructed from the original plus the amendments. Renders through Firecrawl without difficulty, including million-character statutes: the Georgian Tax Code comes back at 1,190,393 characters.
Standing: Maintains the text in force
Cannot be cited for: Three things it must not be cited for. First, it is not free for everything: for some Government resolutions - resolution No 255 of 5 June 2015 on visa-free entry, and resolution No 36 of 21 February 2013 on universal health care - the site serves only the text as originally published and prints დოკუმენტის კონსოლიდირებული ვარიანტის ნახვა ფასიანია, that viewing the consolidated version is a paid service requiring registration and the purchase of a viewing right. A reading of such a page is a reading of the original, however many consolidations have followed, and must be labelled as one. Second, it publishes the consolidated law and not the reasoning: no explanatory memorandum, no case law, no ministerial guidance, and a great deal of Georgian immigration and tax practice sits in orders of the Minister of Finance and the Minister of Internal Affairs which it holds but which are not linked from the parent act. Third, the Georgian pages are the law and the English pages at the matching address are not the same document - see ge-matsne-en. Pages render statutes inside HTML tables, so stored text carries table pipes and <br> markers around the publisher's own words.
We re-read it every 90 days. More about this source
«1\. An international company shall be an enterprise of Georgia, which performs activities defined by an ordinance of the Government of Georgia and earns income solely from these activities. 2\. The status of international company shall be granted to an entity by the Government of Georgia. 3\. Performance by an international company of the activities not defined by an ordinance of the Government of Georgia shall entail cancellation of the status of international company for it as of 1 January of the year the activities were commenced. 4\. An international company may not be set up within a Free Industrial Zone (FIZ). 5\. (Deleted – 14.7.2020, No 6817). 6\. (Deleted – 14.7.2020, No 6817). 7\. The income earned as a result of working for hire at an international company shall be taxed at 5%. 8\. A dividend paid by an international company shall not be taxed at the source and shall not be included in the gross income of a person receiving the dividend. 9\. The object of profit taxation for an international company shall be defined under Article 97(1) of this Code. 10\. The profit tax rate for an international company shall be 5%.»Known to be out of date. The English text matsne serves at this address is the consolidation in force from 25 June 2026 to 30 September 2026. The Georgian at the matching address is the consolidation of 30 September 2026, and the English of that consolidation does not exist: the page for it carries no law, only the notice that the consolidation is underway. Law of Georgia No 1874 of 30 September 2026 is therefore not in this text.
matsne's English of article 23 matches the Georgian on every figure.
Read it at the sourceAbout this source
The same publisher's English rendering of Georgian instruments, served at matsne.gov.ge/en/document/view/<id> - the same document id as the Georgian, so the two texts are one address apart. Where an English consolidation exists it is a full translation of that consolidation, with the same article numbering, the same amending-law footers and the same metadata block. For the Law on the Legal Status of Aliens and Stateless Persons the English kept pace with the Georgian through the amendments of 15 April and 25 June 2026, so the 2026 spouse permit and the interagency marriage commission can be read in both languages.
Standing:
Cannot be cited for: It may never be cited as the law, for four reasons found in the text itself. (1) It lags, silently to a reader who does not look up: on 11 October 2026 the Tax Code in English was the consolidation of 25 June 2026 while the Georgian was that of 30 September 2026, and the Organic Law on Georgian Citizenship in English was the edition of 7 March to 26 June 2025 while the Georgian was 25 June 2026. (2) The newest consolidation of a lagging instrument does not exist in English at all: the English page for Tax Code publication 246 and citizenship publication 12 carries no law, only 'Attention! The consolidation of the document is underway. You are not reading the latest version of the document.' (3) The default English address serves the last complete English edition under the line 'Attention! You are not reading the final edition', which is one line of body text above a million characters of statute. (4) Subparagraph letters are relabelled by alphabetical position rather than transliterated, so Georgian ფ becomes u, ჟ becomes p and თ becomes h - and the trap is live, because the Latin letter that a reader would reach for by sound lands on a different and sometimes repealed subparagraph: English article 99(1)(p) is Georgian 99(1)(ჟ), while Georgian 99(1)(პ) was deleted on 30 May 2018. It also mis-states one amending law's number, printing the law of 30 May 2018 as No 3591 in twelve places and as No 2391 in twelve others where the Georgian prints №2391 throughout, and it loses superscripts: article 21¹ appears as '211' and paragraph 6¹ as '61'. Cite it beside the Georgian, as a translation, never instead of it.
We re-read it every 120 days. More about this source
Practical notes
The ordinance of the Government that names the permitted activities, and the Minister of Finance's rule for applying the 5% employment rate under article 23(14), have not been read here. Neither the list nor the application procedure is published on this record.