Tax residency in Georgia: 183 days, high net worth, and the catch for Europeans

Georgia is attractive tax-wise, but only if you actually become resident. And for people leaving a high-tax country there's a second point that's easy to miss: Georgia is a low-tax country, and that can extend your home-country tax liability beyond the move. This article covers both sides.

When you become a Georgian tax resident

There are two routes into Georgian tax residency:

• The 183-day rule: spend 183 days or more in Georgia within any rolling 12-month period and you are tax resident (Art. 34 Tax Code). The window is rolling, not tied to the calendar year.
• The high-net-worth route (without 183 days): you can become resident on application even without the days, by proving either assets over GEL 3 million or income over GEL 200,000 per year over the last three years. Since April 2023 an additional condition applies: USD 500,000 of Georgian assets and GEL 25,000 of Georgian-source income. The status must be re-applied for annually.

Georgia taxes residents territorially: only Georgian-source income is taxed, the regular income tax rate is 20% (qualifying sole traders use the 1% status instead). Foreign income is generally exempt for residents. The catch is the same everywhere: work you physically perform in Georgia is Georgian-source, even with foreign clients.

The catch for Germans and other Europeans

From a German perspective, Georgia counts as a low-tax country. Someone who moves there while keeping substantial ties to Germany can fall under extended limited tax liability (erweitert beschränkte Steuerpflicht, §2 AStG): Germany then keeps taxing certain German income for up to ten years. There is a double-taxation treaty between Germany and Georgia, which avoids genuine double taxation in many cases, but it doesn't replace a clean exit. Keep a home, family or business back home and you stay taxable there, regardless of Georgia.

So the order matters: end your home-country tax liability cleanly first, then build Georgian residency. (Austria and Switzerland have their own rules; check your own country.)

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Sources

• PwC Worldwide Tax Summaries: Georgia
• Revenue Service of Georgia

This article is a general overview, not tax advice. The rules change and depend on your case. Have your exit and residency checked by a professional before acting.