What Georgian tax residency does not solve

Your home country still applies its own rules

Every country decides for itself who is resident there for tax. Georgia's 183-day test in Tax Code Art. 34(2) answers only Georgia's question. Your home country may still treat you as resident under its own law. If it does, you can be resident in two countries at the same time.

Leaving the tax system of your home country is a separate process under that country's law. We do not describe other countries' rules on this site unless we have a source for them. Ask an adviser in your home country what you need to do to stop being resident there, and in what order.

Exit taxes and controlled foreign company rules

Two kinds of home-country rule often matter to people who move abroad:

• An exit tax charges tax on gains, such as the rise in value of shares, when a resident leaves. Some countries have one and some do not.
• Controlled foreign company (CFC) rules let a country tax its residents on profit kept in a foreign company they control. A Georgian company that pays no profit tax while it keeps profit may fall under such rules while you are still resident at home.

Georgian law has no effect on either. Check whether your home country has these rules before you move assets or set up a company in Georgia.

US citizens

The US tax authority, the IRS, states that US citizens and resident aliens living abroad are subject to tax on worldwide income from all sources. Moving to Georgia does not change that. Georgia's exemption for foreign income in Art. 82(1)(u) removes Georgian tax only.

There is no modern comprehensive tax treaty between the United States and Georgia. The United States is not on the Ministry of Finance list of Georgian treaties. The IRS treaty table (Table 3, updated through 26 September 2025) says in a footnote that the 1973 US-USSR income tax treaty applies to Georgia, among other former Soviet states. That convention is limited in scope.

Double tax treaties

The Ministry of Finance lists 58 double tax avoidance agreements. It says the Multilateral Instrument (MLI), an OECD agreement that updates many treaties at once, covers 34 of them. Partners include:

• the United Kingdom (the 2004 agreement as amended by the 2010 Protocol, listed by HMRC as in force and modified by the MLI);
• Germany (in force 21 December 2007, protocol from 1 January 2015);
• the Netherlands;
• many EU states, plus Switzerland, Norway, Israel, the UAE, Turkey, Ukraine, Japan, Singapore, China and others.

A treaty can reduce double tax when two countries both tax the same income. Each treaty has its own text, and the result depends on its terms. If you plan to rely on one, read it, or ask an adviser who knows both countries. You may need a Georgian tax residency certificate to show your status.

Information exchange (CRS)

The Common Reporting Standard (CRS) is an OECD system under which countries exchange information on financial accounts held by residents of other countries. Georgia joined the CRS Multilateral Competent Authority Agreement, announced by the OECD in November 2022, with first exchanges intended for September 2024.

The OECD Global Forum's 2025 peer review update rated Georgia's legal framework "In Place But Needs Improvement", mainly because sanctions on reporting institutions are incomplete. We saw this rating through a search summary only, because the OECD page blocked our access.

Pensions and social contributions

Georgia's funded pension scheme does not cover most foreigners. The Law on Funded Pension applies to employers, Georgian citizens, and foreign citizens and stateless persons with a permanent residence permit (Art. 1(4)). A foreigner without a permanent residence permit falls outside its scope.

For covered employees, the employer pays 2% and the employee 2% of taxable salary. The state adds 2% on the first GEL 24,000 of annual salary, 1% from GEL 24,000 to GEL 60,000, and nothing above GEL 60,000 (Art. 3(6)). Covered self-employed people, including individual entrepreneurs, may join voluntarily and then pay 4% of their income. See permanent residence in Georgia for how that permit works.

Tax residency gives no right to stay

Being a Georgian tax resident does not let you live in Georgia. The right to stay comes from a visa-free stay, a visa or a residence permit. The reverse is also true: a residence permit does not make you a tax resident. See Georgia tax residency for how the two differ, and our residency guide for the permit routes.

Income Georgia still taxes

Georgian residency is not a full exemption. Georgia taxes salary for work done in Georgia at 20%, and treats a resident's fees from foreign clients as Georgian-source income (Art. 104(1)(a) and (c.g)). See foreign income and Georgian tax.