Ge Corporate Income Tax

---
name: ge-corporate-income-tax
description: "Profit tax (corporate income tax) in Georgia (the country, GE) for tax year 2026, under Chapter XIII of the Tax Code of Georgia. Covers who pays; the distributed-profit model, where a company pays 15% only when it pays dividends, spends money on things unrelated to its business, gives things away free, or exceeds the 1% entertainment cap; the 0.85 gross-up; the 20% annual-profit regime for banks, credit unions, microfinance organisations and loan providers; the international company 5% rate; key exemptions; the monthly return and payment by the 15th; withholding on dividends, interest and royalties (5%) and on other payments to non-residents (10%, or 15% to preferential tax countries); penalty interest of 0.05% a day and the late-filing and understatement fines. Trigger phrases: Georgia profit tax, Estonian model Georgia, distributed profit tax Georgia, 15% Georgia company tax, dividend tax Georgia LLC, rs.ge profit tax return. Out of scope: personal income tax (georgia-income-tax), VA"
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/ge-corporate-income-tax"
  jurisdiction: "GE"
  tax_year: "2026"
  last_updated: "2026-10-31"
  reviewed_by: "Gvantsa Amiridze"
---

# Georgia profit tax (corporate income tax), 2026

Georgian companies pay profit tax under Chapter XIII of the Tax Code of Georgia (articles 96 to 99). The tax authority is the Revenue Service (rs.ge), under the Ministry of Finance. Amounts are in Georgian lari (GEL). The text used here is the consolidated Tax Code on matsne.gov.ge, publication of 15 October 2026 (Law No 1888, published 16 October 2026). Key deadlines were checked against the Georgian original.

Since 1 January 2017 most companies are not taxed on the profit they earn in a year. They are taxed when profit leaves the company: as a dividend, as a payment unrelated to the business, as a free supply, or as entertainment spending over a cap (art. 97(1); transitional rule art. 309(106)). Profit kept in the company is not taxed.

## Who this applies to

- **Profit tax payers**: resident enterprises, and non-resident enterprises that do business in Georgia through a permanent establishment or earn Georgian-source income (art. 96).
- **Resident (Georgian) enterprise**: one whose place of business or place of management is in Georgia (art. 22(1)). "Enterprise" covers Georgian legal entities, foreign companies and similar bodies, and a permanent establishment of a foreign enterprise. An individual entrepreneur is not an enterprise (art. 21).
- **Distributed-profit model**: applies to resident enterprises (art. 97(1)) and to permanent establishments of non-residents (art. 97(3)).
- **Annual-profit model**: banking institutions, credit unions, microfinance organisations and loan providers are taxed on gross income less deductions for the calendar year (art. 97(12)), at 20% (art. 98(4)). So are profits from oil and gas "existing agreements" and the two main pipeline projects (art. 97(8)).
- **Non-profit organisations**: taxed only on spending unrelated to their purpose, on free supplies unrelated to their purpose, and on entertainment over the cap (art. 97(2)).
- **Non-residents without a permanent establishment**: taxed at source on Georgian-source income (arts. 97(4), 134). See Cross-border points.
- **Out of scope here**: individual entrepreneurs, micro and small business status (see georgia-income-tax and georgia-tax-optimization).

## Rates, bands and thresholds

| Item | Rate or amount | Year | Source URL |
|---|---|---|---|
| Standard profit tax rate | 15% | 2026 | https://matsne.gov.ge/en/document/view/1043717?publication=247 (art. 98(1)) |
| Gross-up for distributed-profit items | taxable amount = amount paid / 0.85 | 2026 | same, art. 97(10) |
| Effective rate on the net amount paid | 15 / 85 = about 17.65% | 2026 | derived from arts. 97(10), 98(1) |
| Banks, credit unions, microfinance organisations, loan providers (annual profit) | 20% | 2026 | same, art. 98(4) |
| Slot machine salons and online games of chance (domestic players); the base is bets accepted less winnings paid (art. 97(9^1)) | 20% | 2026 | same, art. 98(6) |
| Online games of chance and betting, profit from foreign-citizen players | 5% | 2026 | same, art. 98(5) |
| Oil and gas "existing agreements" signed before 1 January 1998 | 10% | 2026 | same, art. 98(2) |
| International company (status granted by the Government) | 5%; gross-up / 0.95 | 2026 | same, art. 23(10), (11) |
| Entertainment cap | 1% of prior-year income (1% of expenses if expenses exceed income); first year: 1% of expenses to year end | 2026 | same, art. 98^4(2), (3) |
| Donations to charities not taxed | up to 10% of prior-year net profit | 2026 | same, art. 98^3(3)(a) |
| Withholding on dividends (to individuals, non-profits, non-residents) | 5% | 2026 | same, art. 130(1) |
| Dividends received by a Georgian company (a form listed in art. 2(3) of the Law on Entrepreneurs, other than an individual enterprise) | not taxed at source | 2026 | same, art. 130(2) |
| Dividends paid by a bank, credit union, microfinance organisation or loan provider out of profit earned in 2023 or later | not taxed at source | 2026 | same, art. 130(8) |
| Withholding on interest (to individuals, non-residents without a PE) | 5% | 2026 | same, art. 131(1) |
| Interest paid by a licensed Georgian financial institution | not taxed at source | 2026 | same, art. 131(5) |
| Withholding on royalties paid to non-residents | 5% | 2026 | same, art. 134(1)(b^1) |
| Withholding on royalties paid to resident individuals | 20% | 2026 | same, art. 132(1) |
| Other Georgian-source payments to non-residents | 10% | 2026 | same, art. 134(1)(e) |
| International telecom and transport services paid to non-residents | 10% | 2026 | same, art. 134(1)(c) |
| Interest, royalties and other payments to a person in a preferential tax country | 15% | 2026 | same, art. 134(1^1) |
| Preferential tax country test | no profit tax, or a rate not over 1/3 of the Georgian rate | 2026 | same, art. 98^2(5) |
| Penalty interest on late payment | 0.05% of the unpaid tax per day | 2026 | same, art. 272(4) |

## The taxable base

**What is taxed (distributed-profit model).** Four items, each grossed up by dividing by 0.85 (arts. 97(1), 97(10)):

1. **Distributed profit**: a dividend paid to a partner, in money or in kind (art. 98^1(1)). These are not distributed profit (art. 98^1(2)):
   - a return of capital on liquidation or a share buy-back, up to the partner's contributions;
   - a dividend paid to a company in a form listed in art. 2(3) of the Law on Entrepreneurs (general partnership, limited partnership, LLC, joint-stock company or cooperative), unless the recipient is an individual enterprise or a person exempt from profit tax;
   - passing on a dividend received from a foreign enterprise, unless that enterprise is in a preferential tax country. That amount is treated as paid out first (art. 98^1(5)).
   - Deemed distributions: non-market transactions with related parties that are outside profit tax, controlled transactions that fail the arm's length test, and non-market transactions with exempt persons (art. 98^1(4)).
2. **Costs unrelated to economic activity** (art. 98^2(1)):
   - undocumented costs where documents are required;
   - costs not aimed at profit or income;
   - purchases from a micro business, unless the seller is taxed under the general rule or a consignment note or prescribed document is issued;
   - purchases from a fixed-tax payer within the fixed-tax activity;
   - interest above the annual rate set by the Minister of Finance;
   - payments to a special trade company above customs value.

   Also taxed when made, with a credit or refund when the money comes back (art. 98^2(3), (7) to (9)):
   - loans to individuals or non-residents (not for banks and similar lenders);
   - cash deposits securing a loan to an individual or non-resident partner;
   - loans, advances, fines and debt securities involving a person in a preferential tax country or an exempt person;
   - capital contributions to a non-resident or an exempt person.
3. **Free supplies** of goods, services or money (art. 98^3(1)). A stock shortage counts as a free supply (art. 98^3(2)). These are not taxed (art. 98^3(3)):
   - donations to charities up to 10% of the prior year's net profit;
   - free supplies to the state, a municipality or a legal entity under public law;
   - free supplies to another company inside the distributed-profit model;
   - sureties and easements;
   - food donated under the food-donation law.
4. **Entertainment costs over the cap**: 1% of the prior year's income, or 1% of expenses if expenses exceed income (art. 98^4(2)).

**Non-cash payments** are valued at market price, without VAT (art. 97(7)).

**Exemptions that matter most** (art. 99(1)), and income treated as paid out first (art. 99(3)):

- **Virtual zone person**: profit, and its distribution, from IT it develops and supplies outside Georgia (art. 99(1)(p)).
- **Free Industrial Zone (FIZ) enterprise**: profit from activity permitted in the zone (art. 99(1)(m)).
- **High-mountain settlement enterprise**: distributions for 10 years after it gets the status (art. 99(1)(w)).
- **Special trading company**: distributions from permitted activity (art. 99(1)(s)).
- **Interest from a Georgian-certified financial institution**: distribution of profit from that interest (art. 99(1)(x)).
- **Agricultural cooperative**: primary supply of Georgian agricultural products before 1 January 2028 (art. 99(1)(f)).
- **Tourist zone hotel services**: the relief for profit from hotel services ran only to 1 January 2026, so it does not apply in 2026 (art. 99(1)(q)).

**Losses.** The distributed-profit model has no loss relief, because the tax is not computed on annual profit. For companies on the annual-profit model (banks and similar lenders), a loss carries forward up to five years (art. 121(4)). They can apply to extend this to ten years before the five years expire (art. 122(1)).

**Profit earned before 2017.** If a company pays a dividend out of net profit earned from 1 January 2008 to 1 January 2017, it can set off the profit tax it paid for those years. The set-off is capped at the tax due on the distribution (art. 309(92)).

## Deadlines and filing

| What | When | Source |
|---|---|---|
| Profit tax return (distributed-profit model) | monthly, no later than the 15th of the following month | art. 153(10) |
| Payment of profit tax | within the time set for filing the return, so by the same 15th | art. 62(2) |
| Withholding return on payments made and tax withheld | monthly, by the 15th of the following month | arts. 153(5), 154(4) |
| Payment of tax withheld | to the budget at the time the payment is made; for payments in kind, on the last day of the month | art. 154(3)(a) |
| Annual profit tax return (banks and others outside art. 97(1) to (3)) | before 1 April of the following year (Georgian: "1 აპრილამდე", so by 31 March) | art. 153(1)(b) |
| Current (advance) payments, annual-profit taxpayers | 25% of last year's tax each by 15 May, 15 July, 15 September and 15 December | art. 155(1) |
| Company starting liquidation | notify the tax authority and file a return within 5 business days of registering the start of liquidation | art. 153(3) |
| Non-resident claim to recompute tax withheld on art. 134(1)(c) to (e) income | return by 1 April of the following year | art. 134(3) |

Current payments are not due if there was no taxable profit last year (art. 155(2)). A taxpayer that expects profit to fall by at least 50% can reduce them if it notifies the tax authority before the due date (art. 155(3)).

A company registered before 1 December has a first tax period to 31 December. One registered in December has a first period to the end of the following year (art. 59(2), (3)).

## Penalties and interest

| Offence | Penalty | Source |
|---|---|---|
| Late payment | penalty interest of 0.05% of the unpaid tax for each day late, including the day of payment | art. 272(4) |
| Penalty interest time limit | not charged once 3 years have passed from the day the obligation arose | art. 272(2^1) |
| Late return, up to 2 months late | 5% of the tax due on the return | art. 274(1), Georgian text |
| Late return, more than 2 months late | 10% of the tax due on the return | art. 274(2) |
| Late return showing zero tax | no fine | art. 274(3) |
| Understatement, up to 5% of the declared tax | 10% of the understated tax | art. 275(2^1) |
| Understatement, over 5% and up to 20% | 25% of the understated tax | art. 275(2^2) |
| Understatement, other cases | 50% of the understated tax | art. 275(2) |
| Understatement caused only by a change in the period of the liability | 10% | art. 275(1) |
| Understatement over GEL 100,000 | treated as large-scale tax evasion under criminal law | art. 275(4) |
| Breach of taxpayer registration rules | GEL 500 | art. 273 |

Fines from one audit under art. 275 cannot exceed the tax assessed in that audit (art. 275(5)).

The English translation on matsne still shows the older art. 274(1) wording (5% for each month, capped at 30%). The Georgian original, which is the official text, sets a single 5% fine for a return up to 2 months late.

## Cross-border points

- **Permanent establishment**: a fixed place of business in Georgia, including a dependent agent (art. 29(1)). A construction site, an installation project and a place of management count (art. 29(2)). A permanent establishment is taxed on the same distributed-profit items as a resident. The profit it remits to its head office counts as distributed profit (arts. 97(3), 98^1(3)). Profit it earned before 1 January 2017 is not taxed when distributed (art. 309(92^1)).
- **Withholding on payments to non-residents** without a permanent establishment (art. 134(1)):
  - dividends and interest: 5%;
  - royalties: 5%;
  - international telecom and transport services: 10%;
  - oil and gas subcontractors: 4%;
  - other Georgian-source income: 10%.

  Interest, royalties and other income paid to a person in a preferential tax country is taxed at 15% (art. 134(1^1)).
- **Sale of Georgian shares or property by a non-resident**: taxed on the gain, meaning gross Georgian-source income less related deductions for the calendar year, not at source (art. 97(5), (6)).
- **Preferential tax countries**: payments to them for debt securities, fines, advances, loans and claims are taxed as costs unrelated to business (art. 98^2(3)). The Government publishes the list by ordinance (art. 98^2(10)).
- **Foreign dividends passed on**: a dividend a Georgian company receives from a foreign enterprise, and then pays on, is not distributed profit. This does not apply if the foreign enterprise is in a preferential tax country (art. 98^1(2)(e)).
- **Treaties**: a non-resident claims treaty relief under the procedure in art. 125. Treaty rates are not covered here.
- **Moving management to Georgia**: a foreign company whose place of management moves to Georgia becomes a Georgian enterprise (art. 22(1)). Passing on dividends it received is not distributed profit (art. 98^1(2)(f)).

## Worked examples

### Example 1: an LLC pays a dividend to its owner

A Tbilisi LLC is on the distributed-profit model. In March 2026 it pays its sole owner, a Georgian resident individual, a dividend of GEL 85,000 in cash. It has no other taxable payments that month.

The taxable amount is the dividend grossed up: 85,000 / 0.85 = GEL 100,000 (art. 97(10)). Profit tax at 15% is GEL 15,000 (art. 98(1)). The company also withholds 5% from the dividend, GEL 4,250 (art. 130(1)). The withheld tax goes to the budget when the dividend is paid (art. 154(3)(a)). The profit tax return is filed and the profit tax paid by 15 April 2026, and the withholding return is filed by the same date (arts. 153(5), (10), 62(2)). The owner receives GEL 80,750 and has nothing more to pay on it (art. 130(3)).

```oa-check
name: Georgian LLC, GEL 85,000 dividend to a resident individual, 2026
inputs:
  dividend: 85000
steps:
  - taxable_amount: dividend / 0.85
  - profit_tax: taxable_amount * 0.15
  - dividend_wht: dividend * 0.05
  - net_to_owner: dividend - dividend_wht
  - total_tax: profit_tax + dividend_wht
expected:
  taxable_amount: 100000.00
  profit_tax: 15000.00
  dividend_wht: 4250.00
  net_to_owner: 80750.00
  total_tax: 19250.00
```

### Example 2: a loan to the owner and a dividend partly from a foreign dividend

In June 2026 the same LLC lends GEL 34,000 to its owner, a resident individual. It is not a bank. In the same month it pays a dividend of GEL 51,000. Of this, GEL 17,000 comes from a dividend it received from a foreign subsidiary that the client confirms is not in a preferential tax country.

The loan to an individual is taxed as a cost unrelated to business (art. 98^2(3)(g)). The part of the dividend that passes on a foreign dividend is not distributed profit and counts as paid out first (art. 98^1(2)(e), (5)). So GEL 51,000 - 17,000 = GEL 34,000 of the dividend is taxable. The taxable payments are 34,000 + 34,000 = GEL 68,000, grossed up to GEL 80,000. Profit tax is GEL 12,000.

Withholding at 5% applies to the whole dividend paid to the individual, GEL 2,550 (art. 130(1)). Article 130 has no carve-out for foreign dividends passed on. When the owner repays the loan, the company can set off or reclaim GEL 6,000, the tax on the amount repaid, in that month (art. 98^2(8)).

```oa-check
name: Georgian LLC, loan to owner plus dividend with a foreign-dividend part, 2026
inputs:
  loan_to_owner: 34000
  dividend_paid: 51000
  foreign_dividend_passed_on: 17000
steps:
  - taxable_dividend: dividend_paid - foreign_dividend_passed_on
  - taxable_payments: loan_to_owner + taxable_dividend
  - taxable_amount: taxable_payments / 0.85
  - profit_tax: taxable_amount * 0.15
  - dividend_wht: dividend_paid * 0.05
  - tax_on_loan: loan_to_owner / 0.85 * 0.15
expected:
  taxable_dividend: 34000.00
  taxable_amount: 80000.00
  profit_tax: 12000.00
  dividend_wht: 2550.00
  tax_on_loan: 6000.00
```

## Ask the client first

1. Is the company a bank, credit union, microfinance organisation or loan provider? If so, it pays 20% on annual profit, not the distributed-profit tax.
2. Does it hold a special status: international company, virtual zone person, FIZ enterprise, special trading company or high-mountain settlement enterprise? Ask for the certificate.
3. What left the company this month: dividends, loans to individuals or non-residents, payments to persons in preferential tax countries, free supplies, entertainment?
4. Who receives the dividends: a Georgian company, a resident individual, or a non-resident (and where)?
5. Does any of the profit being paid out come from foreign dividends, or from profit earned before 2017?
6. Are there related-party transactions not at market price?

## Sources

| Source | URL | Read on |
|---|---|---|
| Tax Code of Georgia, consolidated English text, publication of 15 October 2026 (arts. 21 to 23, 29, 59, 62, 96 to 99, 121, 122, 125, 130 to 134, 153 to 155, 272 to 275, 309) | https://matsne.gov.ge/en/document/view/1043717?publication=247 | 2026-10-31 |
| Tax Code of Georgia, Georgian original, same publication (arts. 98, 134, 153, 155, 272, 274, 275) | https://matsne.gov.ge/ka/document/view/1043717?publication=247 | 2026-10-31 |
| Law of Georgia on Information Technology Zones (virtual zone person) | https://matsne.gov.ge/en/document/view/1152405 | 2026-10-31 |

Not yet confirmed: the annual interest rate cap set by the Minister of Finance (art. 98^2(1)(e)); the Government's current list of preferential tax countries (art. 98^2(10)); treaty withholding rates and the art. 125 relief procedure; the list of activities allowed for an international company (Government ordinance, art. 23(15)); transfer pricing documentation rules (arts. 126 to 129, not read); any changes in force from 2027.

## Today's figures and who stands behind this skill

This file is an AI skill (tax rules your AI follows) from OpenAccountants, copied on 2026-10-31. Rates, thresholds and deadlines change. For the current version of this skill, its official sources and the named accountant (if any) who stands behind it, call `get_skill` with slug `ge-corporate-income-tax` on the OpenAccountants connector (https://www.openaccountants.com/connect), or read https://www.openaccountants.com/skills/ge-corporate-income-tax. If neither is available, confirm every figure against the official source pages cited above before relying on it.