HNWI Tax Residency in Georgia: Requirements and Renewal
You want to be taxed as a Georgian resident without spending half the year in the country. Georgia has a route for that, and it runs on money rather than days: a wealth test, property held in Georgia, and one Georgian link. This post sets out both versions of the route, what the Revenue Service does with your file, why you apply again every year, and what Georgian residency then does to your income.
- Georgia can grant tax residency to a high net worth individual under Minister of Finance Order No 60, and that Order sets no minimum number of days in the country.
- The wealth test is confirmed assets over GEL 3,000,000, or annual income over GEL 200,000 during the last 3 tax years before the application.
- Everyone on this route also needs property in Georgia worth at least USD 500,000, plus either a residence permit, residence card or Georgian citizen ID card, or GEL 25,000 of Georgian-source income in the tax year before you apply.
- You file with the Revenue Service and the Minister of Finance grants the residency; a complete file reaches the Minister within 7 working days.
- Residency is granted for 1 tax year, so the whole file is submitted again for every year you want covered.
- Foreign income stays exempt, but once you are resident, services you supply to clients abroad become Georgian-source income taxed at 20%.
HNWI tax residency under Article 34 and Order No 60
The ordinary way into Georgian residency is presence, and the 183-day presence test makes you resident for the whole tax year once your days in the country add up. Article 34 also lets the Minister of Finance grant residency to a high net worth individual, under rules the Minister sets.
Those rules are Minister of Finance Order No 60 of 1 March 2023, in force since 15 April 2023. Nothing under it happens automatically: you apply to the Revenue Service, and the Minister grants residency on the Revenue Service's submission.
Order No 60 contains no day count, no period of stay and no presence requirement of any kind. Presence is exactly what this route replaces: what it tests instead is wealth, property in Georgia and one link to the country.
An earlier joint order, No 991/250 of 2010, ran a version of the same route with no USD 500,000 condition, and it lost force on 14 June 2023.
HNWI requirements in Georgia
Every applicant meets the same wealth test and owns the same minimum property in Georgia. The 2 routes differ only in the Georgian link: one asks for an immigration document, the other for Georgian-source income.
Assets over GEL 3,000,000 or income over GEL 200,000
You count as a high net worth individual on confirmed assets above GEL 3,000,000, or on annual income above GEL 200,000 during the last 3 tax years before the application.
That income is not limited to Georgian sources. Where Order No 60 wants Georgian-source income it says so, and it says so only in the GEL 25,000 condition below.
The Order places no geographic limit on the assets either: it asks for confirmed property and stops there, and the USD 500,000 you hold in Georgia counts towards the GEL 3,000,000 rather than sitting on top of it.
What the Order does not do is name asset types or set a valuation method. It asks only for documents that confirm the property exceeds GEL 3,000,000, or that the income exceeds GEL 200,000, and the one valuation rule it carries is the exchange rate on the day your application arrives. Its wording on the income test reads "annual income during the last 3 years before filing the application exceeds GEL 200,000", without the words "in each year" or "in total", so a file built on income rather than assets is worth confirming with the Revenue Service before you file.
USD 500,000 of property in Georgia
Both routes require property in Georgia worth at least USD 500,000 or the equivalent in lari.
The Order writes that condition as property owned in Georgia, with no restriction to real estate and no list of qualifying assets, so its words do not shut out deposits, shares or securities.
The tense matters. The Order says you own the property and values everything at the date the Revenue Service receives your application, so it has to be yours when the application is considered, and no holding period runs before that.
Route A: a residence permit, residence card or Georgian ID card
On the first route, a high net worth individual with the Georgian property qualifies by holding a Georgian residence permit, a residence card or a Georgian citizen's ID card.
A residence permit is an immigration document and does not by itself make anyone a tax resident. Article 34 counts days of physical presence, and the permit matters here only as one of the eligibility documents on this route.
Route B: GEL 25,000 of Georgian-source income
On the second route the same individual qualifies instead on at least GEL 25,000 of Georgian-source income received in the last tax year before the application. The year that counts is the one before you file, not the year you file in.
Georgian-source income is defined in the Tax Code: services actually rendered in Georgia count, and so does rent from immovable property in Georgia that is let out.
| Condition | Route A | Route B |
|---|---|---|
| Wealth test | Assets over GEL 3,000,000, or income over GEL 200,000 during the last 3 tax years | Same |
| Property in Georgia | At least USD 500,000 or the equivalent in lari | Same |
| Georgian link | Residence permit, residence card or Georgian citizen ID card | At least GEL 25,000 of Georgian-source income in the last tax year before applying |
| Days in Georgia | None in the conditions | None in the conditions |
| Granted for | 1 tax year | 1 tax year |
How to apply for HNWI tax residency
Filing with the Revenue Service
You file with the Revenue Service, and the Order lets you do it in person or through a representative, on paper or in electronic form. Living outside Georgia is therefore no obstacle to filing.
Currency conversion on the day your application arrives
Values in a foreign currency are converted at the National Bank of Georgia rate on the day the Revenue Service receives the application.
That fixes the lari figures for your file on a single date. The USD 500,000 of Georgian property and any foreign-currency assets behind the GEL 3,000,000 are measured at that day's rate, not at the rate on the day you bought them.
What happens after you file
- You file the application with the Revenue Service, together with the documents that confirm the thresholds.
- If a document is not in the file, you are given a period of up to 30 days to supply it.
- Once the file is complete, the Revenue Service sends its submission to the Minister of Finance within 7 working days.
- The Minister of Finance grants the residency.
- If you have no Georgian taxpayer number, you receive one along with a residency certificate.
Order No 60 sets no deadline inside the tax year by which the application has to be filed.
Renewal: HNWI residency covers 1 tax year
Residency under Order No 60 is granted per tax year, and the documents are submitted again on every repeat request. For income tax, an individual's year is the calendar year, 1 January to 31 December.
A residency certificate can be requested only for the year in which the application was filed, so a year that has closed cannot be picked up afterwards through this route.
Each year's file is converted at the National Bank rate on its own day of receipt. A currency that has fallen against the lari since last year can put the same flat, or the same portfolio, under the threshold this time.
Route B needs more attention here than Route A. Every application looks at the last tax year before it, so staying on that route means at least GEL 25,000 of Georgian-source income in the year before each application.
- Confirmed assets over GEL 3,000,000, or annual income over GEL 200,000 during the 3 tax years before that application.
- Property in Georgia worth at least USD 500,000 on the day the new application is received.
- Route A: a residence permit, residence card or Georgian citizen ID card. Route B: at least GEL 25,000 of Georgian-source income in the tax year just ended.
- Every foreign-currency figure converted again, at the National Bank rate on that day.
Tax residency certificate and taxpayer number
A person granted residency who has no Georgian taxpayer number receives a residency certificate and a taxpayer number with the grant. For an individual who is not a Georgian citizen, that number is the 9-digit identification number the Tax Code provides for.
The certificate is issued by the Revenue Service in an approved form, and both the application and the certificate are electronic. You apply with your name and full address in Georgian and in English and your Georgian taxpayer identification number. The Georgian tax residency certificate that comes back is what a foreign tax office asks for when it wants proof of where you are taxed.
Where your home country insists on its own residency form instead, the Revenue Service confirms residency on that form with signature and seal wherever the form provides a field for it, and the form needs a notarised Georgian translation.
Taxes you pay as an HNWI tax resident
Income from outside Georgia
Income of a resident individual that is not Georgian-source, gains included, is exempt from Georgian income tax. Dividends from a non-resident company, and interest from a foreign bank or a foreign bond issuer with no Georgian permanent establishment, fall outside every clause of the source article, so for a Georgian resident they are foreign income and carry no Georgian tax. An individual's income from supplying crypto assets is exempt on the same reasoning.
A non-resident is taxed only on Georgian-source income, so on genuinely foreign income the bill is the same either way. What residency changes is the source rule for the services you sell, and the certificate that tells another country where you are taxed.
Services you supply to clients abroad
Once you are a Georgian resident, a service you supply to a recipient in another state is Georgian-source income, unless you supply it through a permanent establishment in another country that confirms the service was delivered there. Article 104 of the Tax Code makes each of its service clauses independently sufficient, so physical performance in Georgia is one way in, not a condition.
Where the client pays you makes no difference, because the place the amount is received is not taken into account in deciding source. Georgian-source income of an individual is taxed at the general rate of 20%.
Which of your income streams change source on the day you become resident depends on how each one is earned and who receives it, and David Sisvadze can check each stream against the source rules and set the answer out in a written opinion he signs.
As a non-resident, a service you sell is Georgian-source when it is actually rendered in Georgia, and work done for a client abroad from a laptop in Lisbon is outside Georgian income tax.
As a Georgian resident, that same invoice to that same client is Georgian-source income, unless it runs through your own permanent establishment in another country. The rate on it is 20%, and no bank account arrangement changes the answer.
Georgian dividends and interest
Dividends paid by a Georgian company to an individual are taxed at 5% at source, and that withholding is final, so the dividend never joins your gross income. Interest paid to an individual works the same way at 5%, also final.
Interest from a licensed financial institution, a bank deposit being the ordinary case, is not taxed at source and is not included in gross income at all. Where Route B's GEL 25,000 came from Georgian dividends or interest, that 5% is the whole of the Georgian tax on it.
The annual income tax return
A resident with income that was not taxed at source files an annual income tax return and pays the tax on it by 31 March of the following year, the last day the Revenue Service's own brochure gives for both.
A late return costs 5% of the tax due on it up to 2 months late and 10% after that. Where the tax due on the return is zero, there is no late filing fine.
Property tax on Georgian real estate
If you hold the USD 500,000 as a flat or a house, that real estate is taxable property for an individual. Property tax is a local tax, so your municipal council sets the rate within the limits the Tax Code lays down.
A family with income of GEL 100,000 or more pays 0.8% to 1% of the property's market value at the end of the year. Family income counts all income, exempt income included, so the foreign income that pays no Georgian income tax still puts a household in that band.
The tax is pro rata to the time the property was owned during the year. The return falls due on 1 November and the payment on 15 November, and the Revenue Service is allowed to assess the tax itself from the previous year's data.
Say the market value of your flat at the end of the year is GEL 1,400,000, and your family income for the year is above GEL 100,000.
At 0.8% the property tax is GEL 11,200. At 1% it is GEL 14,000. Which end of that band applies depends on the rate your municipality has set. Had you owned the flat for half the year, the charge would be half of that.
HNWI tax residency and double tax treaties
Georgia has 58 double tax treaties in force, listed on the Ministry of Finance treaty page, and relief under them is claimed by the procedure in Order No 633. The United States and Russia are not on that list.
Georgian residency does not settle where you are resident for treaty purposes. Under Georgia's treaties with the United Kingdom and with Germany, a person both states treat as resident is placed by 4 tests taken in order: where a permanent home is available to them; failing that, the state their personal and economic relations are closer to; failing that, habitual abode; and last of all, nationality. Where none of the 4 decides it, the 2 tax authorities settle the case between them by agreement.
The German treaty goes further on that last step: until the authorities reach agreement, the person may claim no benefit the treaty provides.
183-day rule vs the HNWI route
| Point | 183-day test | HNWI route |
|---|---|---|
| Legal basis | Tax Code Article 34(2) | Article 34(6) and Order No 60 |
| Days in Georgia | 183 or more in any continuous 12-month period | None in the conditions |
| Financial conditions | None | Assets over GEL 3,000,000 or income over GEL 200,000; USD 500,000 of property in Georgia |
| Georgian link | Physical presence | Permit, residence card or citizen ID card, or GEL 25,000 of Georgian-source income |
| How you get it | From the facts, with no application | Application to the Revenue Service, granted by the Minister of Finance |
| Period | The whole tax year the 12-month period ends in | 1 tax year, applied for again each year |
Someone moving to Georgia who will be in the country for 183 days or more in a continuous 12-month period is resident for that year on the presence test alone, and the HNWI file is work that buys nothing. The route is for people whose days are spent somewhere else.
Frequently asked questions
Can I become a tax resident of Georgia without spending 183 days there?
Yes. Order No 60 sets no minimum number of days in Georgia: the rule contains no day count, no period of stay and no presence requirement at all. What it asks for instead is the wealth test, USD 500,000 of property in Georgia and one Georgian link.
What are the HNWI tax residency requirements in Georgia?
The wealth test first: confirmed property of more than GEL 3,000,000 in value, or annual income of more than GEL 200,000, during the 3 tax years before you apply. Then property in Georgia of at least USD 500,000 in value. And one Georgian link, which is either an immigration document (a residence permit, a residence card or a Georgian citizen ID card) or Georgian-source income of GEL 25,000 or more in the preceding tax year. All 3 parts have to be met.
Do I need a Georgian residence permit to qualify as an HNWI?
No. A residence permit, residence card or citizen ID card is 1 of the 2 ways to hold the Georgian link. The other is Georgian-source income of GEL 25,000 or more in the tax year before you apply, which suits an owner of Georgian property who lets it out.
How long does it take to get HNWI tax residency in Georgia?
Order No 60 sets 2 deadlines, both on the Revenue Service's side of the file. A complete application goes to the Minister of Finance within 7 working days, and an incomplete one gets a period of up to 30 days for the gap to be filled.
Do I have to renew HNWI tax residency every year?
Yes. Residency is granted for 1 tax year and the documents are submitted again on every repeat request. Each year's foreign-currency values are converted afresh at the National Bank of Georgia rate on the day that year's application is received, so the thresholds are tested at that year's rate.
Can I apply for HNWI tax residency from abroad?
Yes. The application can be filed with the Revenue Service through a representative, on paper or electronically, and the Order attaches no presence requirement to the filing.
Can I get HNWI tax residency for a previous year?
No. A residency certificate can be requested only for the year in which the application was filed, so an application filed in 2027 cannot produce a certificate for 2026.
Do HNWI tax residents pay tax on foreign income in Georgia?
No. Income of a resident individual that is not Georgian-source, gains included, is exempt. The catch is what counts as Georgian-source: services you supply to a recipient in another state become Georgian-source once you are resident, unless they go through your permanent establishment abroad, and that income is taxed at 20%.
Will I get a Georgian taxpayer number with HNWI residency?
Yes, if you do not already have one. A person granted residency without a taxpayer number receives one together with the residency certificate, and for an individual who is not a Georgian citizen it is the 9-digit identification number.
Do I pay property tax on my Georgian property as an HNWI resident?
If the property is real estate, yes. Real estate owned by an individual is taxable property, and a family with income of GEL 100,000 or more pays 0.8% to 1% of its market value at the end of the year. Family income counts exempt income too, the return is due by 1 November and the payment by 15 November.