Country-wide policy
Virtual Zone Person: an Exemption for a Company's Profit, Not for a Person's Income
The IT status that circulates as a personal tax route is neither personal nor an income tax provision. Article 8(35) of the Tax Code defines a virtual zone person as a legal person which carries out information technology activity and has been granted the corresponding status, and article 8(36) defines that activity as studying, supporting, developing, designing, producing and introducing computer information systems that result in software products. The benefit is in article 99(1), the list of profit tax exemptions: profit, and the distribution of profit, from the supply outside Georgia of information technologies created by a virtual zone legal person. So it exempts a company's profit distribution, it only reaches supplies made outside Georgia, and it does nothing at all for an individual's income tax. A natural person who holds the status is holding it through a company.
Topics it changes
What it requires
- A legal person, not a natural person
- Information technology activity as article 8(36) defines it
- The status itself, which article 8(35) assumes rather than grants
- Supply of the information technologies outside Georgia
At a glance
- Who can hold it
- A legal person
Article 8(35) of the Tax Code. An entrepreneur natural person cannot: that route is Small Business Status.
- What is exempt
- Profit, and profit distribution, from supplying outside Georgia information technologies created by the virtual zone legal person
Article 99(1)(ჟ) of the Tax Code - lettered p in matsne's English. Supplies inside Georgia are not covered.
- Which tax
- Profit tax, not income tax
Article 99 is the profit tax exemption article. Nothing in articles 79 to 82 gives a virtual zone person's owner an income tax exemption.
What the law says
«35\. ვირტუალური ზონის პირი – იურიდიული პირი, რომელიც ახორციელებს საინფორმაციო ტექნოლოგიურ საქმიანობას და მინიჭებული აქვს შესაბამისი სტატუსი. 36\. საინფორმაციო ტექნოლოგიები – კომპიუტერული საინფორმაციო სისტემების შესწავლა, მხარდაჭერა, განვითარება, დიზაინი, წარმოება და დანერგვა, რის შედეგადაც მიიღება პროგრამული უზრუნველყოფის პროდუქტები.»Our translation - not official
35. Virtual zone person - a legal person which carries out information technology activity and has been granted the corresponding status. 36. Information technologies - the study, support, development, design, production and introduction of computer information systems, as a result of which software products are obtained.
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
«ჟ) ვირტუალური ზონის იურიდიული პირის მიერ შექმნილი საინფორმაციო ტექნოლოგიების საქართველოს ფარგლების გარეთ მიწოდებით მიღებული მოგება (მოგების განაწილება);»Our translation - not official
(ჟ) profit (distribution of profit) received from the supply outside the borders of Georgia of information technologies created by a virtual zone legal person;
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
«p) profit (distribution of profit) earned from the supply of information technologies outside Georgia developed by a legal entity of a virtual zone;»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.
The letter is the trap. In the Georgian this is subparagraph ჟ, the sixteenth letter of the Georgian alphabet, and the English prints p, the sixteenth of the Latin one. Georgian subparagraph პ - which transliterates as p and is what a reader guessing by sound would reach for - is the one immediately above it, and it was deleted on 30 May 2018.
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
We did not find in the Tax Code the body that grants the status or the procedure for applying: article 8(35) speaks of a person who 'has been granted the corresponding status' and leaves the granting elsewhere. No fee or timescale is published here.