Foreign Income Tax in Georgia: What Is Exempt, What Is Not
You live in Georgia and the money arrives from somewhere else: foreign clients, a foreign employer, dividends, a pension. Georgia exempts a resident's foreign-source income, so the only question that matters is which of your income is foreign-source and which is not. The Tax Code answers it stream by stream, and for work you do yourself it does not turn on where your client is. Here is the rule and where it bites.
- A Georgian tax resident pays no income tax on income that is not Georgian-source. A non-resident pays only on Georgian-source income.
- Where the money lands makes no difference. A foreign client, an invoice in dollars and a foreign bank account do not make income foreign.
- Work you do for foreign clients while you are resident in Georgia is Georgian-source income, taxed at the general rate of 20%.
- Small business status brings that same work to 1% on income up to GEL 500,000 a year, but only from the day you apply, and consulting cannot use it.
- Dividends, interest, royalties, rent and gains from abroad, and a foreign pension, sit outside Article 104 and are exempt in a resident's hands.
- Exempt foreign income still counts as family income for property tax, where the exemption stops at GEL 40,000.
How Georgia taxes foreign income
Georgia taxes a resident individual on Georgian-source income and lets the rest go. Income, including gains, of a resident that is not Georgian-source is exempt under Article 82 of the Tax Code, and a non-resident pays income tax only on Georgian-source income. Residency decides who is in scope; the source of each stream decides what is taxed.
You are a resident for the whole tax year once your days in Georgia reach 183 in any continuous 12 calendar month period that ends in that year. The count runs on physical presence alone, so a visa, a residence permit or a registered address neither creates residency nor prevents it.
Where income is Georgian-source, the general personal income tax rate is 20%. Special rates sit under it for dividends, interest, residential rent and property gains, so the rate follows the kind of income rather than a single flat number.
| Situation | Resident | Non-resident |
|---|---|---|
| Income that is not Georgian-source | Exempt | Not taxed in Georgia |
| Georgian-source income | Taxed, general rate 20% | Taxed |
| Salary from a foreign employer for work done in Georgia | Taxed, no short-stay relief | Exempt if the work in Georgia lasts no more than 30 calendar days in the tax year and no Georgian permanent establishment bears the cost |
What makes income Georgian-source under Article 104
Article 104 of the Tax Code lists what counts as Georgian-source income, clause by clause. Income that fits none of those clauses is not Georgian-source, which is why the exemption in Article 82 does so much work for people living here. The services clause is written in 8 limbs, and 2 of them catch most of what an expat earns from abroad.
Where the money is paid does not decide it
In determining the source of income under Article 104, the place where the amount of income is received is not taken into account. A foreign bank account does not make income foreign, and a Georgian one does not make it Georgian. Nor does the client's country, the currency or the payment platform.
Services performed in Georgia
The first limb is the plain one: services actually rendered in Georgia are treated as delivered in Georgia, and the income from them is Georgian-source. If you were sitting in Tbilisi when you did the work, the income is sourced here.
Services a Georgian resident supplies to a client abroad
The second limb reaches further. Where the service provider and the service recipient are in different states and the provider is a Georgian resident, the income is Georgian-source, unless the provider delivers the service through a permanent establishment in the other country which confirms that the service was delivered there. It sets no condition about where the work was physically done, so a Georgian resident's service to a client abroad stays Georgian-source even during a month of working from another country, as long as there is no foreign permanent establishment behind it.
Applied to the usual case, that means work you do from Georgia for foreign clients is Georgian-source income, not foreign income. Article 104 also carries a residual clause for other income earned from carrying on activities in Georgia, and its scope is what the words carry: the activity itself has to be carried on here.
Work you do from Georgia for foreign clients
Freelancers and individual entrepreneurs invoicing abroad
Say you are resident in Tbilisi and bill foreign clients GEL 100,000 of taxable income in a year. Both limbs point the same way, so that is Georgian-source income and the general rate applies: GEL 20,000 of income tax.
VAT is a separate question with a friendlier answer. The place of supply of a service to a business customer is where the customer is established, so most services you sell to foreign businesses fall outside Georgian VAT and do not count toward the GEL 100,000 registration threshold, which is measured over any 12 consecutive calendar months rather than a calendar year.
Salary from a foreign employer while you live in Georgia
Salary for employment physically performed in Georgia is Georgian-source income, whoever pays it and wherever it is paid. The 30-day relief in the table above is written for non-residents, and a resident employee gets no equivalent.
Nobody withholds it for you. Where the employer is a non-resident with no Georgian presence, the withholding duty expressly excludes that salary, so a resident working remotely for a foreign employer declares the income and pays the tax personally. It goes on the annual return; there is no monthly income tax return for this case.
The 1% regime for the same work
Small business status is granted to an entrepreneur natural person and taxes income under the regime at 1%. The taxable income under the regime is Georgian-source income other than salary and the types the Government lists, so fees from foreign clients for work you do here sit squarely inside it: the status works because the income is Georgian-source, not in spite of it.
The status covers gross income from economic activity up to GEL 500,000 a calendar year, with GEL 700,000 allowed to wine tourism and agro tourism operators. Exceed it and 1% gives way to 3%, applying to the whole of the month the excess is recorded in and to every month left in that year. Neither the Code nor the ministerial order gives any deduction against that base, so the 1% and the GEL 500,000 limit are measured on income received under the regime, not on profit. On the same GEL 100,000, the tax is GEL 1,000 instead of GEL 20,000.
2 limits matter before anyone reorganises around it. Some activities are excluded outright, among them licensed and permitted activities, currency exchange, medical, architectural, advocacy or notary, audit and consulting work including tax consultants, gambling and the provision of personnel, which means a consultant cannot hold the status at all. And the status is not retroactive: you register as an individual entrepreneur first, the status applies from the day the application is filed, and income earned earlier in the same year stays taxed under the previous regime.
A Georgian company is the other route. It is taxed on distributed profit rather than on retained profit, at 15%, and dividends it then pays to an individual are taxed at 5% at source.
Dividends, interest, pensions and other income from abroad
Passive income is where the exemption does what people expect. Each type has its own clause in Article 104, and each of those clauses ties the source to a Georgian payer or to property located in Georgia, which foreign investments are not.
| Income | From a Georgian payer or Georgian property | From abroad |
|---|---|---|
| Dividends | 5% withheld at source, final for a resident individual | Georgian-source only if the payer is a resident legal person, so exempt |
| Interest | 5% at source, final; nothing on interest from a licensed financial institution such as a bank deposit | Sourced to the payer, so interest from a foreign bank or bond issuer with no Georgian permanent establishment is exempt |
| Royalties | 20% at source for a resident individual not registered for VAT | Exempt where the payer is a non-resident with no Georgian permanent establishment |
| Rent from residential property | 5% where the landlord claims no deductions | Exempt where the property is outside Georgia |
| Gain on selling a home | Exempt after more than 2 years of ownership, otherwise 5% | Exempt where the asset is outside Georgia |
| Pension | Georgian-source only if a resident pays it | Exempt |
Pensions from abroad
A pension or a scholarship is Georgian-source only where a resident pays it. A state pension, an occupational pension or an annuity from a foreign fund or insurer therefore falls outside Article 104 and is exempt in your hands as a Georgian resident. What the paying country does with it is a separate question, answered by its own law and by any treaty.
A foreign company you run from Georgia
Dividends from a foreign company are foreign-source, but the company may not be foreign for Georgian purposes. An enterprise is a Georgian enterprise if its place of business or its place of management is in Georgia, and the place of management is where the management body actually exercises its functions, wherever the income is received. So a company registered abroad but directed from Tbilisi is a Georgian enterprise and is taxed here on the profit tax objects. The tax authority may also disregard an operation with no material economic effect, or re-qualify one whose form does not match its content.
Crypto gains
Income of an individual from the supply of crypto assets is exempt from income tax because it is not Georgian-source, which the Ministry of Finance settled in Public Ruling No 201. The ruling decides 3 questions and the income tax one is about a disposal, which leaves crypto received as payment for work outside it. Staking rewards and trading carried on as a business are outside it too.
Foreign income on your Georgian return and your property tax
The annual return
Resident individuals whose income is not taxed at source in Georgia file an annual income tax return, and the Revenue Service reads the deadline as 31 March of the following year. The tax is paid by the same day, because the Code sets no separate payment date for it.
Exempt income is declared and then removed, not left off the form. Box 15 of the return carries gross income including income that Georgian tax legislation exempts, box 17 carries income a resident received outside Georgia, and box 18 takes the Article 82(1) reliefs back out again. A resident whose only income is exempt is inside the words of the filing article, so the return is due when nothing was withheld and nothing is payable. Nothing in the Code fines the omission: an unfiled return counts as one showing zero, and there is no fine where the tax due is zero.
Property tax counts your exempt foreign income
Property tax is a local tax, introduced by the municipal council within the limits the Code sets, and individuals pay it on owned real estate and on the listed vehicles. A family whose income for the year before the current one came to GEL 40,000 or less pays nothing on property other than land. Above that, the rate is 0.05% to 0.2% of market value at year end for families under GEL 100,000, and 0.8% to 1% for families at GEL 100,000 or more.
Here is the sting. Family income counts all income, including exempt income, so foreign-source income that pays no income tax at all still decides which band you are in. A small business status holder counts only 25% of the income taxed under the 1% regime toward it.
A family's income in 2025 was GEL 120,000, all of it foreign-source and all of it exempt from income tax. At the end of 2026 it owns a Tbilisi flat with a market value of GEL 400,000.
The GEL 40,000 exemption is long gone, and GEL 120,000 puts the family in the GEL 100,000 or more band, where the rate is 0.8% to 1% of market value. The property tax is GEL 3,200 to GEL 4,000, depending on the rate the council has set. The return is due by 1 November and the payment by 15 November.
Tax in the other country, and double tax treaties
Georgia's exemption settles Georgian tax and nothing else. The country paying you applies its own law, so a pension, a dividend or a salary can be taxable at source while Georgia takes nothing, and the answers are reached independently.
Georgia has 58 treaties on the avoidance of double taxation in force, and the Ministry of Finance publishes the list. The United States and Russia are not on it. Where a treaty does apply, it decides which of the 2 states may tax each stream, and on the Georgian side the relief is claimed under Order No 633.
To use a treaty abroad you usually have to prove you are Georgian resident. The Revenue Service issues a tax residency certificate on an electronic application giving your name and address in Georgian and English and your Georgian taxpayer identification number, and where the other country has its own residency form with a field for it, the Revenue Service confirms your residency on that form instead. The Tax Code gives an individual no foreign tax credit article: Article 124 speaks of enterprises and profit tax, and a resident needs no credit on genuinely foreign income because it is already exempt.
If you have treated work from Georgia as foreign income
Both limitation periods start at the close of the calendar year in which the liability arose. From then the Revenue Service has 3 years to assess tax and serve a tax demand, and 3 years to impose sanctions. If less than a year of that is left and you file a return, including an amended one, for that period, both periods extend by 1 year.
Late payment interest runs at 0.05% a day on the tax left unpaid, and the day you pay is itself an overdue day. GEL 20,000 of unpaid income tax therefore costs GEL 10 a day, or GEL 3,650 over a year. It stops accruing 3 years after the obligation to charge it arose.
The late return is charged on top: 5% of the tax due under the return if it is up to 2 months late and 10% if it is later, so GEL 1,000 or GEL 2,000 on the same GEL 20,000. There is no fine where the tax due under the return is zero.
Understating is a separate offence from filing late. Where a return was filed but left the income out, the fine is 50% of the understatement, or 10% or 25% where the understatement is a smaller share of the tax declared. Correcting yourself reaches that fine: the fine for information shown incorrectly on a return is not imposed on a person who filed an amended return before the decision to conduct an audit was served or a tax offence report was drawn up. It does not erase a late filing fine, because the sanctions apply separately.
Nor does the 1% regime reach back, so registering now fixes next year and not last year.
Where fees, a salary and investment income from abroad run across several years, each stream has to be sourced on its own facts, and David Sisvadze can set out where yours stand in a written opinion he signs, drawing on 6 years inside the Revenue Service of Georgia.
The source of each income stream is decided separately, so one wrong assumption about the easiest stream does not travel to the others.
Frequently asked questions
Is foreign income tax free in Georgia?
For a Georgian tax resident, income that is not Georgian-source is exempt, so genuinely foreign income is taxed at 0%. The catch is what counts as foreign. Services you perform in Georgia, and services you supply as a Georgian resident to a client in another state, are Georgian-source income however foreign the client looks.
If a foreign client pays into my foreign bank account, is that foreign income?
No. In deciding the source of income, the place where the amount is received is not taken into account. If you did the work as a Georgian resident, the fee is Georgian-source income and the general rate of 20% applies unless you hold a special status.
Do I pay Georgian tax on a salary from a foreign employer while I work remotely from Tbilisi?
Yes. Salary for employment physically performed in Georgia is Georgian-source income whoever pays it. A non-resident employer with no Georgian presence does not withhold it, so you declare it yourself on the annual return by 31 March and pay by the same day.
Are dividends and interest from abroad taxed in Georgia?
No. Dividends are Georgian-source only where a resident legal person pays them, and interest is sourced to the payer, so a foreign company's dividend and a foreign bank's interest are exempt for a resident individual. The same income from a Georgian payer is taxed at 5% at source, and that withholding is final.
Is a foreign pension taxed in Georgia?
No. A pension is Georgian-source only where a resident pays it, so a pension or annuity from a foreign state, fund or insurer is exempt in Georgia. Whether the paying country taxes it is decided by that country's law and by any treaty with Georgia.
Do I have to declare foreign income on my Georgian tax return?
Yes. Exempt income is declared and then relieved rather than omitted: the annual return's gross income box includes exempt income, a separate box carries income a resident received outside Georgia, and the Article 82(1) reliefs come out further down. A resident with income not taxed at source is inside the filing article, so the return covers foreign income even when no tax follows from it.
Can I pay 1% instead of 20% on income from foreign clients?
Often, yes. Small business status taxes income under the regime at 1% up to GEL 500,000 of gross income a calendar year, and fees from foreign clients for work done in Georgia fall inside it. It is closed to consulting and the other excluded activities, and it runs only from the day you apply.
Do I pay tax in Georgia on crypto gains?
No. Income of an individual from the supply of crypto assets is exempt, because the Ministry of Finance treats it as not Georgian-source. That ruling is about disposals only: it says nothing about coins received as payment for work, staking rewards or trading carried on as a business.
Does foreign income count toward property tax in Georgia?
Yes. Family income for property tax counts all income, including exempt income, so foreign-source income can push a family past GEL 40,000 into the charge and past GEL 100,000 into the 0.8% to 1% band, even when the income tax on it is zero.
Is foreign income taxed if I am not a Georgian tax resident?
No. A non-resident pays Georgian income tax only on Georgian-source income. Residency follows the day count: 183 days or more of presence within any continuous 12 calendar month period ending in the tax year makes you resident for the whole of it.