Foreign income and Georgian tax residency
What the Art. 82(1)(u) exemption covers, why service fees from foreign clients can still be taxed, and rates on investment income and crypto.
Last verified 2026-10-20Next review 2027-01-203 official sources
Whether Georgia works for you depends on how you earnTalk it through
A Georgian tax resident pays no Georgian income tax on income that is not Georgian-source (Tax Code Art. 82(1)(u)). Foreign dividends and gains on foreign assets fall under this exemption. Fees a resident earns for services to foreign clients usually do not, because Art. 104 treats them as Georgian-source income.
The exemption in Art. 82(1)(u)
Art. 82(1)(u) exempts "income (including gain) received by a resident natural person, which does not belong to Georgian source income". A natural person is an individual, as opposed to a company. So the exemption depends on one question: is the income Georgian-source or not?
Art. 104 of the Tax Code answers that question. Two points in it catch people out.
- Art. 104(2) says the place where you receive the money does not matter. Foreign income paid into a Georgian bank account stays foreign income. Georgian income paid into a foreign account stays Georgian income.
- Art. 104(1) sets out where income comes from by type. For services, the test is where the law treats the service as delivered. The client's country does not decide it.
Why fees from foreign clients can be Georgian-source
Under Art. 104(1)(c.g), a service counts as delivered in Georgia when the provider and the client are in different states and the provider is a Georgian resident. The exception is a service delivered through the provider's permanent establishment abroad (a fixed place of business in another country).
For a freelancer, consultant or contractor who lives in Georgia and is tax resident, this has a direct result. Fees from clients in Germany, the United States or anywhere else are Georgian-source income. The Art. 82(1)(u) exemption does not cover them. Without another regime, they fall under the standard 20% rate in Art. 81(1).
This is the reason many freelancers register as an individual entrepreneur and apply for small business status. That status taxes Georgian-source turnover at 1% up to GEL 500,000 a year. See individual entrepreneur and small business status.
Salary works in a similar way. Under Art. 104(1)(a), employment income for work done in Georgia is Georgian-source. An employee of a foreign company who works from Georgia earns Georgian-source salary, taxed at 20%.
One narrow exception applies to non-residents. Salary of a non-resident who works in Georgia for no more than 30 calendar days in a tax year, paid by a non-resident employer, is exempt (Art. 82(1)(y)).
Investment income: rates and exemptions
| Income | Treatment for a resident individual | Tax Code |
|---|---|---|
| Dividends from a foreign company | Foreign-source, exempt | Art. 82(1)(u) |
| Dividends from a Georgian company | 5% at source, not taxed again | Art. 130(1), 130(3) |
| Dividends from an International Company or a Free Industrial Zone enterprise | Not taxed at source | Art. 23(8), 130(7) |
| Interest from a Georgian payer | 5% at source | Art. 131(1) |
| Interest from a licensed Georgian financial institution, such as bank deposits | Not taxed at source and not in gross income | Art. 131(5) |
| Interest on Georgian government, National Bank of Georgia and listed international financial institution debt securities | Exempt | Art. 82(1)(s) |
| Gains on shares of a Georgian company | Georgian-source, 20% unless exempt | Art. 104(1)(f), 81(1) |
| Gains on foreign assets | Foreign-source, exempt | Art. 82(1)(u) |
| Renting residential space for living | 5% of gross income, no deductions | Art. 81(2) |
| Other rental income | 20% | Art. 81(1) |
Capital gains on Georgian assets
Gains on Georgian assets are taxed as ordinary income at 20% unless an exemption applies. Art. 82(1)(f) exempts gains on:
- a residential apartment or house with its land, owned for more than 2 years;
- a vehicle owned for more than 6 months after registration;
- other assets owned for more than 2 years, unless used for economic activity. Holding securities only to receive dividends or interest does not count as economic activity.
Where the exemption does not apply, the surplus from selling a residential apartment or house with its land, or a vehicle, is taxed at 5% (Art. 81(3)).
Gifts and inheritance
Gifts and inheritance from first- and second-line heirs are exempt (Art. 82(1)(g)). From third- and fourth-line heirs, up to GEL 150,000 a year is exempt (Art. 82(1)(i)). From other individuals, up to GEL 1,000 a year is exempt (Art. 82(1)(h)).
Crypto
The Tax Code settles the VAT side. Crypto assets are not goods (Art. 160(2)), and transferring ownership of crypto is not a service (Art. 160^1(4)(b)). Sales of crypto are therefore outside VAT.
The income tax side rests on a secondary source. Eurofast, Bloomberg Tax and others report a Ministry of Finance public decision of 28 June 2019. According to them, it treats income from an individual's sale of crypto assets as non-Georgian-source. For a resident, that would make the gain exempt under Art. 82(1)(u).
What is not yet established. We could not find the text of the 28 June 2019 public decision on the Revenue Service's information portal, so the crypto position above comes from secondary sources only. It is also disputed whether crypto sales count toward an individual entrepreneur's GEL 500,000 small business limit. One source says they do, while staying tax free. We have not confirmed either point.
What this means in practice
The exemption helps most when your income is passive and comes from abroad: foreign dividends and gains on foreign assets. It helps least when you earn by working from Georgia, whether as an employee or a freelancer, because Art. 104 makes that income Georgian-source.
Georgia's exemption also says nothing about what your home country taxes. If your home country still treats you as resident, it may tax the same income. See what Georgian tax residency does not solve. For the main rules, return to Georgia tax residency.
Tax Code version. This page uses the English Tax Code consolidated to 15 October 2026. An amendment of 15 October 2026 (Law No 1888-VIმს-XIმპ) is not yet in the English text. We have not checked whether it changes Arts. 81, 82, 104, 130 or 131.
Common questions
- Is my freelance income from foreign clients tax free in Georgia?
- Usually not. Under Art. 104(1)(c.g) of the Tax Code, a service counts as delivered in Georgia when the provider is a Georgian resident and the client is in another country, unless it is provided through a permanent establishment abroad. That makes the fees Georgian-source income, which the Art. 82(1)(u) exemption does not cover.
- Are foreign dividends taxed for a Georgian tax resident?
- No. Dividends from a foreign company are foreign-source income, and Art. 82(1)(u) exempts foreign-source income of a resident individual. Dividends from a Georgian company are taxed at 5% at source under Art. 130(1).
- Does it matter if foreign income is paid into a Georgian bank account?
- No. Art. 104(2) of the Tax Code says the place where the money is received does not decide whether income is Georgian-source.
- How is crypto taxed in Georgia?
- The Tax Code keeps crypto sales outside VAT. For income tax, secondary sources report a Ministry of Finance public decision of 28 June 2019 that treats an individual's gains from selling crypto as non-Georgian-source, so exempt for residents. We could not read the decision itself.
Whether Georgia works for you depends on how you earn
Where you live is only half of it. We can walk through your position with you, including the cases where Georgian tax residency does not give the result people expect. This is general information, not tax advice for your circumstances.
Sources
Every legal, fee and procedural statement on this page is taken from the sources below and was checked on 2026-10-20. Where they change, this page changes.
- Tax Code of Georgia (Legislative Herald of Georgia) — Tax residency, income tax, exemptions and small business status
- Eurofast: features of taxation of crypto-currency in Georgia (24 March 2020) — Ministry of Finance public decision of 28 June 2019 on crypto sales as non-Georgian-source income
- Bloomberg Tax: taxation of cryptocurrency in Georgia — Income tax treatment of crypto sales by individuals
Related
This page is general information about Georgian rules as published by the authorities named above. It is not legal or tax advice for your circumstances, and immigration outcomes depend on your nationality, documents and individual case. See our legal and tax information disclaimer.