Crypto Tax in Georgia: The 0% Rule and Where It Stops
Crypto gains of an individual are not taxed in Georgia, and the reason has nothing to do with a crypto rule. It is a decision about where the income arises, taken by the Ministry of Finance in 2019 and still the basis today. This post sets out what that exemption covers, where it stops, and what a crypto holder in Georgia still files.
- Sell crypto as an individual and the income is exempt from income tax, so the disposal is taxed at 0%.
- The reason is source. Nothing in the source rules makes income from supplying a crypto asset Georgian-source, and a resident individual pays nothing on income that is not.
- Exchanging crypto assets for national or foreign currency is not subject to VAT.
- Public Ruling No 201 decides 3 questions, and crypto paid for work, staking rewards and trading as a business are not among them.
- Georgia decides Georgian tax only, and residency here follows from 183 days or more of presence in a rolling 12 month period.
Is crypto tax free in Georgia?
For an individual, income from the supply of crypto assets is exempt from income tax, so the rate on a disposal is 0%.
The instrument behind that is Public Ruling No 201 of the Minister of Finance, issued on 28 June 2019, published on 1 July 2019, with no amendment or repeal recorded since. It is a public ruling rather than a law, and it decides 3 questions: VAT on the supply of a crypto asset, income tax on the income received from that supply, and VAT on supplying computing power for mining.
This is the individual's position, not a company's. A Georgian company is taxed on distributed profit rather than on profit as it is earned, at 15%, and the dividend then carries a further 5% at source when it reaches an individual.
Why the rate is 0% and not 20%
The general rate on an individual's taxable income is 20%, and personal income tax in Georgia reaches everything the Code treats as arising here. A resident individual is exempt on income that is not Georgian-source, gains included, so the whole question is which side of the source line a crypto disposal falls on.
The ruling puts it on the exempt side, and the reasoning is narrow. No provision of Article 104 directly attributes income from the supply of a crypto asset to a Georgian source.
A crypto asset has no physical form, is not located in a particular place, is not deposited in an account at a financial institution, its issuer as a rule cannot be established, and the place of the transaction practically cannot be determined, because supply and exchange happen in virtual space between members of a virtual community. On those facts the activity is held not to be carried out on the territory of Georgia.
So the 0% is a conclusion about where income arises, not a concession to crypto holders. The Code's own crypto provisions sit in its VAT part, while Article 104 opens by limiting itself to the income and profit tax part, so they settle nothing about source.
What Ruling 201 does not cover
The ruling answers the 3 questions it set itself and no others. Crypto paid to you for work, rewards from mining and staking, and trading as a business all sit outside those answers.
| Situation | Position | Source |
|---|---|---|
| Selling crypto assets for national or foreign currency | Exempt from income tax, 0% | Ruling 201, section 3(b) |
| VAT on that exchange | Not a taxable transaction | Ruling 201, section 3(a) |
| Supplying computing power for mining | Outside Georgian VAT where the recipient is abroad, 18% where the recipient is in Georgia | Ruling 201, section 3(c) |
| Crypto received for work done from Georgia | Georgian-source income under the general rules | Tax Code, Article 104 |
| Mining rewards, staking rewards, airdrops, lending yield | Not addressed | No primary source |
| Trading crypto as a business | Not addressed | No primary source |
Crypto paid to you for work
Under the Tax Code, Georgian-source income includes services actually rendered in Georgia, and services a Georgian resident supplies to a recipient in another state unless they go through a permanent establishment abroad. Where the money is received does not matter, so work you do from Georgia for foreign clients is Georgian-source income.
Settling that invoice in USDT rather than in dollars changes the asset you hold, not the source of the income. The rate is 20% under the general rules, or 1% on turnover for an individual entrepreneur holding Small Business Status, whose base is Georgian-source income.
Say you sell crypto you bought 2 years earlier for a gain of GEL 40,000, and in the same year invoice a foreign client GEL 60,000 for design work you did from Tbilisi, settled in USDT.
- The GEL 40,000 gain is exempt. Income from the supply of crypto assets is not Georgian-source income.
- The GEL 60,000 is Georgian-source income, because you performed the work here. Under the general rules that is GEL 12,000 of tax at 20%.
- As an individual entrepreneur with Small Business Status, the same GEL 60,000 is taxed at 1%, which is GEL 600.
Staking, mining and airdrops
The ruling does not address coins received from mining, staking rewards, airdrops or lending yield. Mining appears in it only as a VAT question: supplying computing power is outside Georgian VAT where the recipient is registered abroad with no Georgian place of management or permanent establishment, and taxable at 18% where the recipient is in Georgia.
The income tax reasoning does not reach that far. It turns on a place of transaction that cannot be determined, and that fact is absent when the mining hardware sits at a known address in Tbilisi. Receipts of this kind have to be tested against the catch-all in Article 104 and, for staking or lending yield, against the services and interest limbs.
No provision of the Tax Code and nothing in the ruling settles the point, so an advance ruling on your own facts is the only answer you can rely on.
Trading as a business
The Code does not say at what point buying and selling crypto stops being investing and becomes a business. Economic activity is any activity carried out to obtain income or compensation, whatever its result, and neither that definition nor the VAT chapter sets a numeric or frequency test for when an individual's dealing becomes systematic. The tests are qualitative: the one-off or irregular character of the activity, and whether property is used to obtain regular income.
Which side of that line your own trading sits on is decided on what you actually do, so you can send us the facts and get a written opinion signed by David Sisvadze.
Small Business Status does not settle it either. Crypto assets are named in none of the 12 income types that Resolution No 415 excludes from the 1% regime, unlike real estate, vehicles and securities. But the 1% base is limited to Georgian-source income, and a crypto disposal is the one thing the ruling says is not that.
The costly mistake is treating an invoice settled in crypto as an exempt disposal. The exemption covers the supply of a crypto asset itself, and the ruling was never asked about anything else. Work you did from Georgia is Georgian-source income whatever the client paid you in, so leaving it off the return leaves tax undeclared rather than exempt.
VAT on crypto
The supply of a crypto asset, meaning its exchange for national or foreign currency, is not a VAT taxable transaction. Under the current Tax Code, crypto assets are not goods and transferring ownership of a crypto asset is not a supply of services.
The reverse charge is the VAT rule that does reach crypto traders. Services supplied in Georgia by a taxable person not established in Georgia are taxed at 18% by the customer acting as tax agent, whether or not that customer is registered for VAT.
The tax agent is any person established in Georgia except a free industrial zone enterprise and an individual who is not an entrepreneur. So a private investor paying exchange or platform fees falls outside the charge, and an individual entrepreneur paying the same fees does not.
Tax residency and the 0% rate
The exemption decides Georgian tax and nothing else. A non-resident is taxed here on Georgian-source income alone, and gains nothing extra from a ruling that puts crypto outside Georgian source.
Georgian tax residency is decided by days in the country: 183 of them inside a rolling 12 month period make you resident for the whole tax year, and any part of a day here counts as a full one.
There is a second route that does not count days at all. The high net worth route turns on asset or income thresholds instead, and adds property in Georgia plus either a Georgian residence document or Georgian-source income in the year before you apply.
Double tax treaties and crypto
The Ministry of Finance treaty list shows 58 treaties on avoidance of double taxation in force. The United States and Russia are not on it, so an American or a Russian in Tbilisi has no treaty to fall back on from the Georgian side.
Neither the United Kingdom treaty nor the Germany treaty names crypto. Under both, a gain on any other property is taxable only in the state where the person disposing of it is resident, and income not dealt with in the earlier articles is taxable only in the recipient's state of residence unless it is effectively connected with a permanent establishment. A crypto gain points the same way down either route.
Treaty relief is claimed under Order No 633 of the Minister of Finance, with a residency certificate that the Revenue Service issues electronically in the approved form.
What you still have to file
Exempt income does not remove the return. Resident individuals whose income is not taxed at source file an annual income tax return, and the Code makes no carve-out for income that happens to be exempt. The deadline is 31 March, and the tax is paid by the same day.
The return form takes exempt income in and out again. Box 15 is gross income received in any form or from any activity, including income that Georgian tax legislation exempts, and box 18 subtracts the Article 82(1) reliefs, which is where an exempt crypto gain comes back out.
| What happened | Charge |
|---|---|
| Return up to 2 months late | 5% of the tax due under the return |
| Return more than 2 months late | 10% of the tax due under the return |
| Return late, tax due zero | No fine |
| Tax paid late | 0.05% of the unpaid tax for each overdue day |
Both fines run on the tax due under the return, so a year of exempt crypto gains and nothing else carries no fine. The Revenue Service does not have unlimited time to reopen a year: its window to assess a liability and serve a demand closes 3 years after the end of the calendar year the liability arose in.
Frequently asked questions
Is crypto tax free in Georgia?
For an individual, yes. Income from the supply of crypto assets is exempt, because the source rules do not place it in Georgia and a resident individual pays nothing on income that is not Georgian-source. The exemption covers the disposal itself, not everything that produces crypto.
Do I have to be a Georgian tax resident to pay 0% on crypto?
No. A resident is exempt on income that is not Georgian-source, and a non-resident is taxed here on Georgian-source income only, so the gain is untaxed in Georgia either way. What residency changes is who else can tax it, because Georgia settles Georgian tax and nothing more, and the country that treats you as resident applies its own rules to the same gain.
Is crypto subject to VAT in Georgia?
No. Exchanging a crypto asset for national or foreign currency is not a VAT taxable transaction, and the current Tax Code treats crypto assets as neither goods nor a service. Buying services from a foreign platform is a separate question, because that can trigger the 18% reverse charge for anyone except an individual who is not an entrepreneur.
Do I pay tax if I am paid in crypto for my work?
Yes, at the ordinary rate for the work. Services actually rendered in Georgia are Georgian-source income, and so are services a Georgian resident supplies to a client abroad unless they run through a permanent establishment abroad. Where the payment lands and what it is denominated in change nothing, so that is 20% under the general rules, or 1% on turnover with Small Business Status.
Is crypto mining taxed in Georgia?
Ruling 201 treats mining only as a VAT question, and supplying computing power is outside Georgian VAT where the recipient is abroad and taxable at 18% where the recipient is in Georgia. The income tax treatment of the coins a miner receives is settled neither by the Tax Code nor by the ruling, so the only firm answer on your own setup comes from an advance ruling.
Do I pay tax on staking rewards in Georgia?
No primary source answers it. Ruling 201 covers disposals of crypto assets and does not address staking rewards, airdrops or lending yield. Until that gap is closed, staking income is a question for an advance ruling rather than a settled 0%.
Do I have to declare crypto gains on a Georgian tax return?
If you file a return at all, exempt income belongs in it. Gross income in box 15 includes income the legislation exempts, and box 18 removes the Article 82(1) reliefs, so an exempt crypto gain is declared and then deducted rather than left off. The deadline is 31 March.