Double Tax Treaties (DTAA) in Georgia: The Full Country List and How They Work (2026)

A double taxation treaty (DTT) (also referred to as a double taxation agreement (DTA) or double taxation avoidance agreement (DTAA)) is an agreement between two countries that prevents the same income from being taxed twice and allocates taxing rights between them to reduce double taxation and combat tax evasion.

Georgia has an extensive treaty network, with 58 double taxation treaties currently in force, all broadly based on the OECD Model Tax Convention. These treaties are an important complement to Georgia’s territorial tax system  for individuals and businesses with cross-border income, investments or commercial activities.

What a treaty does

Although each treaty differs in its details, Georgia’s double taxation treaties are all broadly based on the OECD Model Tax Convention and serve the same core purposes.

They:

• allocate taxing rights between the two countries for different categories of income, such as employment income, business profits, dividends, interest, royalties and capital gains, determining whether the source state, the state of residence, or both may tax the income;
• limit withholding tax on cross-border dividends, interest and royalties, often reducing the applicable rate below domestic law and, under some Georgian treaties, to 0%; and
• prevent double taxation by providing tie-breaker rules where an individual is treated as resident in both countries and by requiring the residence state to grant relief—typically through a foreign tax credit—where the same income is taxed in both jurisdictions.

The key point is that a treaty does not eliminate tax. It determines which country has the right to tax particular income and ensures that the same income is not taxed twice.

Georgia’s double taxation treaty network

Georgia currently has 58 double taxation treaties in force with the following countries:

Armenia, Austria, Azerbaijan, Bahrain, Belarus, Belgium, Bulgaria, China, Croatia, Cyprus, Czech Republic, Denmark, Egypt, Estonia, Finland, France, Germany, Greece, Hong Kong, Hungary, Iceland, India, Iran, Ireland, Israel, Italy, Japan, Kazakhstan, South Korea, Kuwait, Kyrgyzstan, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Moldova, Netherlands, Norway, Poland, Portugal, Qatar, Romania, San Marino, Saudi Arabia, Serbia, Singapore, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey, Turkmenistan, Ukraine, United Arab Emirates, United Kingdom, and Uzbekistan.

The applicable withholding tax rates and permanent establishment thresholds vary from treaty to treaty and depend on the type of income concerned.

Several treaties—including those with Bahrain, Cyprus, Estonia, Liechtenstein, Malta, Qatar, San Marino, Singapore, and the United Arab Emirates—provide for 0% withholding tax on certain categories of dividends, interest or royalties where the relevant treaty conditions are met. Other treaties prescribe rates of 5%, 10% or higher.

The Ministry of Finance publishes the text of each treaty together with a country-specific summary of the applicable withholding tax rates. Always check the relevant treaty before relying on a particular rate, as the applicable treatment depends on both the treaty provisions and the facts of the particular case.

Claiming treaty benefits

The procedure for claiming relief under a double taxation treaty is governed by Order No. 633 of the Minister of Finance of 28 December 2011, which regulates the application of treaty benefits and the refund of tax overpaid by non-residents in Georgia.

In practice, the process usually involves two steps:

1. Obtain a tax residency certificate. The taxpayer must obtain a tax residency certificate from the competent tax authority of their country of residence (or from the Revenue Service, where Georgian tax residence is being claimed). This certificate confirms eligibility to claim treaty benefits. See Tax Residency in Georgia.
2. Claim the treaty benefit. Where the necessary documentation is available, the payer may apply the reduced treaty withholding tax rate when making the payment. If the domestic withholding tax has already been deducted, the recipient may instead apply for a refund under Order No. 633, subject to the prescribed conditions and procedures.

As the required documentation and procedural deadlines vary depending on the circumstances, taxpayers should verify the applicable requirements before relying on treaty relief.

The Multilateral Instrument (MLI)

Georgia’s tax treaty network is also affected by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).

The MLI currently modifies 34 of Georgia’s 58 double taxation treaties by introducing internationally agreed anti-abuse rules without requiring each treaty to be renegotiated individually.

The most significant change is the Principal Purpose Test (PPT). Under this rule, treaty benefits may be denied where obtaining those benefits was one of the principal purposes of an arrangement or transaction, unless granting the benefit is consistent with the object and purpose of the treaty.

For treaties covered by the MLI, the applicable rules are the original treaty as modified by the MLI. The Ministry of Finance publishes these consolidated versions as “synthesised texts”, which should be consulted alongside the original treaty.

Final points

A double taxation treaty is designed to prevent double taxation, not to eliminate tax altogether. While a treaty may reduce withholding taxes, resolve dual tax residence or provide relief through a foreign tax credit, income may still be taxable in one or both countries.

Before relying on a treaty, check the relevant treaty, the MLI (where applicable), and ensure you have the necessary tax residency certificate and supporting documentation.

This guide provides general information only and does not constitute legal or tax advice. As treaty provisions, MLI modifications and administrative practice may change, always verify the current position using the Ministry of Finance’s official publications Ministry of Finance list before taking actions.

Frequently asked questions

How many double-tax treaties does Georgia have?

Fifty-eight treaties on the avoidance of double taxation are currently in force, according to the Ministry of Finance of Georgia. They are all based on the OECD Model Tax Convention, which allocates taxing rights between the two countries and provides for relief so that the same income is not taxed twice.

What do these treaties actually do for me?

Three main things. They allocate the right to tax a given type of income between Georgia and the other country; they cap the withholding tax the source country can charge on cross-border dividends, interest and royalties (often well below domestic rates, sometimes to 0%); and they provide tie-breaker rules to decide a single country of residence where you would otherwise be resident in both. Where income is still taxable in both states, the treaty gives relief — typically a credit in the residence country for tax paid in the source country.

How do I claim treaty benefits in Georgia?

Benefits are claimed under the procedure set out in Decree N633 of the Minister of Finance (28 December 2011), which governs how relief under a double-taxation treaty is applied and how tax paid by non-residents in Georgia can be repaid. In practice you need to establish residency with a tax-residency certificate and follow the decree's documentation steps; for cross-border payments the payer often applies the reduced treaty rate at source on the strength of the right paperwork.

Do I need a tax-residency certificate to use a treaty?

Generally yes. A treaty allocates rights between residents of the two countries, so to claim Georgian treaty benefits you normally have to prove you are a Georgian tax resident with a certificate from the Revenue Service — and to claim the other country's side you prove residence there. The certificate is the document foreign tax authorities and payers rely on. See the tax residency guide for how to obtain one.

What is the MLI and does it affect Georgia's treaties?

The MLI is the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. Georgia signed it on 7 June 2017 and the Parliament ratified it on 27 December 2018. It modifies 34 of Georgia's 58 treaties, adding minimum-standard anti-abuse rules — most importantly a principal-purpose test that can deny treaty benefits to arrangements set up mainly to obtain them. For an MLI-covered treaty, read the treaty together with the MLI's synthesised text.

Does a treaty mean I pay no tax?

No. A treaty prevents double taxation; it does not create a tax-free zone. It decides which country taxes what and reduces or eliminates certain withholding taxes, but you can still owe tax — in one country, the other, or both with a credit. Treaties also increasingly contain anti-abuse rules (via the MLI) that deny benefits to purely artificial structures. Use treaties to avoid being taxed twice, not as a standalone avoidance tool.

Where can I read the actual treaty texts and rates?

The Ministry of Finance publishes the official list, the individual treaty texts (including MLI synthesised texts where applicable) and a summary table of withholding-tax rates on dividends, interest and royalties for each partner country on its Double Taxation Avoidance Treaty page. Always check the specific treaty — and the MLI text where it applies — because rates and conditions vary by country and by type of income.