Georgia offers new tax incentives for foreign IT and shipping companies

By Gela Barshovi, international and Georgian tax adviser and managing partner at TPsolution, Tbilisi, Georgia

On 8 October, Georgia’s government published decree #619, providing new tax incentives for foreign and Georgian companies involved in shipping and information technology.

Decree #619 supplements article 23 of the Georgian tax code.

Georgia is receiving greater attention from the international business community as it is becoming an attractive investment destination with low or no taxes and easy regulations.

Indeed, Georgia offers many tax incentives for both Individuals and legal entities, starting from Georgia’s special corporate income tax regime under which corporate income tax is payable only upon distributions of dividends to shareholders.

Also, there is 0% taxation of individuals on foreign source income and 1% taxation on Georgian source income up to 500 000 Georgian Lari (approx. USD 157 000) per annum and many other benefits.

Additional tax benefits for investment are now in place from 8 October.

For these companies, a corporate income tax rate of 5% (instead of 15%) will apply. Wage tax will be assessed at a 5% rate instead of 20%. Moreover, withholding tax on dividend distributions will be 0% instead of 5%.

In addition, these companies will be partly exempted from property tax and can decrease the basis of corporate income tax with salary and R&D expenses.

The most important preconditions for obtaining a status of “international company” and thereby benefit from tax incentives is that an applicant has at least 2 years’ experience of operating in at least one of the above-mentioned businesses. Also, they must demonstrate business substance in Georgia (expenses accrued in Georgia, hired staff present in the country, etc.). In other words, “letter box” companies will not qualify as “international companies.”

It is important to note that Georgian tax law already provides tax exemptions for IT enterprises. In particular, companies that provide certain types of IT services in Georgia abroad can obtain a certificate of “Virtual Zone Person” (VZP) and enjoy a full exemption from corporate income tax in Georgia.

However, VZPs do not qualify for tax incentives on dividends, wages, and property as international companies will.

The new tax regime for international companies should incentivize multinationals to relocate their IT service centers to Georgia. Not only will they save tax, but wages and salaries for IT staff are much lower in Georgia than in most developed countries.

Similarly, shipping/marine businesses might reduce considerable expenses if they shift their place of management to Georgia.