International Company Status in Georgia: The Benefits, the Two-Year Test and the Real Team
RIGHTSIDE INSIGHTS · INTERNATIONAL COMPANY · 2026
The 5% headline is appealing. The more valuable question is whether your company has the history, activity and people in Georgia to keep the status year after year.
What this status was designed to encourage
Georgia’s International Company regime was introduced for specified activities, including a broad set of IT services and certain maritime activities. It is a special status of a Georgian enterprise, not a separate kind of company. Ordinance No. 619 defines permitted activities and expenses; Article 23 of the Tax Code sets the principal tax benefits. The policy aim is clear in the structure of the rules: attract an actual operating team and its work to Georgia, not simply a foreign business address on a Georgian registration form.
The tax result is a package, not a single rate
The Tax Code sets a 5% profit-tax rate for an International Company’s taxable distributed profit, rather than the ordinary 15%. Eligible income from employment with the company is taxed at 5% rather than the ordinary 20%. Dividends paid by an IC are exempt from source withholding under the special rule. Property intended or used for permitted activity is exempt from property tax, with land excluded.
The company may also reduce the taxable distributed-profit amount by specified expenses incurred in Georgia under the statutory procedure. The ordinance lists qualifying salary expenses for a hired Georgian citizen and specified research, design and experimental development costs in the permitted field. The detailed deduction should be modelled with payroll and project records; it is not an unrestricted deduction for every wage or overseas R&D invoice.
Why payroll matters. A software centre that pays a substantial Georgian team may value the reduced employment rate more than the difference between 0% and 5% company profit tax. Compare the whole structure—salary, distributions and operating costs—before selecting a status.
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Who meets the two-year test?
Ordinance No. 619 generally requires at least two years’ experience in an eligible activity. The applicant’s own history may satisfy this. Certain structures can rely on the experience of a qualifying foreign enterprise, including a Georgian representative operation or a majority-owner route, but the relationships and activities must meet the ordinance’s wording. It is unsafe to assume that a newly formed Georgian LLC inherits the history of any overseas shareholder. Bring corporate ownership documents, prior contracts, invoices and proof of the prior work into the analysis.
What counts as permitted IT?
The ordinance includes software publishing, computer games, programming, computer consultancy, digital products, website development, hosting, remote maintenance, software access and other listed digital activities. It is broader than the product-focused VZP exemption, but it is still a closed legal list, not a benefit for anything marketed as “technology”. The earlier source article described IT activities under service agreements when the scheme was new. Since the ordinance has since been amended, a company should classify its actual contracts under the current permitted-activity text, not rely on an old promotional summary.
Evidence that Georgia is the operating centre
The ordinance requires the principal income-generating permitted activity to be carried out in Georgia with adequate qualified human resources and operating costs. TPsolution’s later comparison describes an administrative expectation that relevant staff be physically present in Georgia for most of the year. That is a practice point to assess with the law, not a substitute for it. Employment contracts, payroll, work-location records, premises and project evidence should show what the team actually does here.
Income from other activities is tightly limited. Ordinance No. 619 allows non-permitted revenue only up to 2% of annual revenue from permitted activities, excluding VAT, under its specified conditions. A small side product or consulting line can grow across the threshold without management noticing. Monitor revenue by activity monthly. The Tax Code and ordinance provide for revocation when conditions fail; the timing can have substantial tax consequences.
How status is granted and maintained
- Register the Georgian enterprise and determine the correct eligible activity under Ordinance No. 619.
- Assemble the two-year history, corporate relationship evidence, actual and legal addresses, activity and service-location information, employee qualifications and cost records.
- Submit the application to the Revenue Service. The Government of Georgia grants or refuses the status on the basis of the procedure.
- After approval, maintain a documented Georgian operation, track the 2% limit and correctly administer the 5% salary rate, profit tax, dividend treatment and any property exemption.
An International Company still needs to consider VAT, foreign supplier withholding, payroll reporting and other ordinary duties. The special rates do not remove them. A company that is too new for IC may assess VZP during its early years if its software work meets that regime’s separate conditions; obtaining the later status requires a fresh application, and VZP status can cease when IC is granted.
General information as of October 2026. The result for a particular taxpayer depends on the current law, supporting documents and the facts of the activity.