International Company Status in Georgia: 5% tax regime for IT and maritime firms

Georgia offers a dedicated preferential tax regime — International Company Status — for companies working in qualifying information-technology and maritime services. A company that holds the status pays sharply reduced rates: profit tax and salary income tax both drop to 5%, most business property is exempt from property tax, and dividends paid out are exempt. The framework is set out in Government of Georgia Ordinance No 619 of 8 October 2020, which approves the procedure for granting the status, the list of permitted activities, and the deductible expenses, working together with the Tax Code of Georgia.

What the status is

For IT companies whose income comes from software supplied abroad, the Virtual Zone Person regime is the main alternative to compare against.

International Company Status is granted to a Georgian enterprise that carries out specific permitted activities. It is not a company type you register at the outset — it is a status layered on top of an existing Georgian company, granted by a decision of the Government of Georgia. Once granted, it applies for an indefinite term and takes effect from the beginning of the month in which it is granted. The Revenue Service maintains a unified electronic register of companies that hold the status

The tax benefits

The point of the regime is the reduced tax burden under the Tax Code:

• Profit (corporate income) tax of 5%, instead of the standard 15%. Georgia taxes corporate profit on distribution (the “Estonian model”), so the 5% applies when profit is distributed or otherwise treated as distributed. The taxable amount is grossed up — the payment made or cost incurred is divided by 0.95 before the rate is applied.
• Personal income tax of 5% on salaries, instead of the usual 20%, for income from employment at the international company.
• Exemption from property tax (except on land) where the property is intended for, or used in, the company’s permitted activities.
• Dividend exemption: a dividend paid by an international company is not taxed at source and is not included in the gross income of the person who receives it.

Who is eligible

Under Annex 1 of the Ordinance, the status may be granted to a Georgian enterprise in any of these cases:

• it has at least two years of experience carrying out the permitted activity on which the application is based; or
• it is the representative in Georgia of a non-resident enterprise that has at least two years of experience in that permitted activity; or
• more than 50% of its shares are owned by partner enterprises (each separately), where there are at least two years of experience in the permitted activity.

Beyond the track record, the company must have real substance in Georgia. It has to carry out the permitted activity in Georgia, conduct its basic income-generating activity there, employ adequate human resources with the necessary qualifications, and cover appropriate operating costs. The status is only available to a company whose profit is taxed under the distributed-profit object of taxation (Article 97(1) of the Tax Code).

Permitted activities

Annex 2 of the Ordinance lists the activities a holder may provide. They fall into two groups.

Information technology and digital services, including software release and the release of computer games and other software (classification codes 58.2, 58.21, 58.29); computer programming, consulting and related activities (codes 62.0 and 62.01–62.09); the production and delivery of digital products including software support and updates; website development and delivery; web hosting and remote maintenance of software and hardware; remote system administration; online delivery of allocated memory; granting access to or downloading software and updates; and a range of related online services. For these IT services, the activity must be rendered on the basis of a service contract.

Maritime services, covering commercial and maintenance services by a shipowner or connected to ship ownership: ship rental with or without a crew (bareboat charter); route planning and analysis; giving route instructions to a ship’s captain as agreed with the charterer; counting laytime (stallia) and analysing disbursement reports; managing cargo-claim, commercial, legal and chartering disputes; organising new-build orders and the sale and purchase of used ships; supervising a ship’s physical condition and supplying technical parts or provisions; coordinating shipbuilding, docking and repair; and ensuring compliance with the ISM Code and the requirements of flag- and port-state control and classification societies.

The 2% limit on other income

A company can hold the status and still earn a little income outside the permitted activities — but only within a tight margin. Revenue from non-permitted activities (excluding VAT) must not exceed 2% of total revenue from the permitted activities in a calendar year. Exceeding that threshold is a ground for revoking the status.

Deductible expenses

Annex 3 lets an international company reduce the distributed-profit amount taxable by profit tax for two categories of expense incurred in Georgia: salaries paid to hired Georgian citizens, and the cost of scientific-research, design and experimental-construction services in the field of the company’s permitted activities. These reductions lower the base on which the 5% profit tax is charged.

How to apply

Applications go to the Revenue Service (the legal entity under public law within the Ministry of Finance), on the form — written or electronic — established by the Minister of Finance. The application states the company’s registration data, legal and actual addresses, the permitted activity it relies on, and where the services are provided, and it is accompanied by documents proving the relevant experience.

The Revenue Service checks the application against the rules within 10 days. If something is missing it can set a deadline (up to 10 days) to fix it. If the application complies, the Revenue Service forwards it, with the materials, to the Ministry of Finance, which submits it with a proposal to the Government of Georgia. The decision to grant — or refuse — the status is the Government’s, made by ordinance.

Losing the status

The status is revoked in three situations: the company applies to give it up; its non-permitted income exceeds the 2% threshold; or it no longer meets the eligibility and substance conditions. The timing matters. Voluntary revocation takes effect from the start of the month in which the decision is made. But revocation for breaching the 2% limit, or for failing the conditions, is retroactive to the date the status was originally granted — which can expose the whole period to the standard rates. Revocation is decided by the Government of Georgia on the recommendation of the Ministry of Finance.

A note on amendments

Ordinance No 619 has been amended several times since 2020, most recently by Ordinance No 420 of 24 September 2025. The permitted-activity list and conditions can change, and the consolidated edition in force on the date you apply is what governs. Always check the current consolidated text of the Ordinance and the Tax Code, and confirm the procedure with the Revenue Service, before relying on the status.

Frequently asked questions

Who can get International Company Status in Georgia?

A Georgian enterprise that carries out one of the permitted IT or maritime activities and has at least two years of experience in it. The two-year track record can come from the company itself, from a non-resident enterprise it represents in Georgia, or from partner enterprises that each separately own more than 50% of it. The company must also conduct its core income-generating activity in Georgia with adequate qualified staff and real operating costs.

What taxes does an international company pay?

Profit (corporate income) tax is 5% instead of the standard 15%, charged on distribution under Georgia's distributed-profit model. Salaries are taxed at 5% personal income tax instead of 20%. The company is exempt from property tax (except on land) for property used in its permitted activities, and dividends it distributes are not taxed at source and are not included in the recipient's gross income.

Which activities qualify?

Two broad groups. IT: software release (including games), computer programming and consulting, delivery of digital products and updates, website development, web hosting, remote system administration and similar online services. Maritime: commercial and technical services connected to ship ownership, such as bareboat chartering, route planning, ship sale-and-purchase brokerage, supervising shipbuilding and repair, and ensuring ISM Code compliance. The full list is in Annex 2 of Ordinance No 619.

How do I apply for the status?

You apply to the Revenue Service (under the Ministry of Finance) on the form set by the Minister of Finance, identifying the permitted activity and where the services are provided, with documents proving the two-year experience. The Revenue Service checks the application within 10 days and, if it complies, forwards it through the Ministry of Finance to the Government of Georgia, which makes the final decision by ordinance.

Can an international company earn income from other, non-permitted activities?

Only within a narrow tolerance. Revenue from activities other than the permitted ones (excluding VAT) must not exceed 2% of total revenue from the permitted activities in a calendar year. Crossing that threshold is a ground to revoke the status — and revocation in that case takes effect retroactively, from the date the status was originally granted.

Is the status permanent?

It is granted for an indefinite term and takes effect from the start of the month in which it is granted. But it can be revoked — on the company's own request, if non-permitted income exceeds the 2% threshold, or if the company stops meeting the eligibility and substance conditions. Voluntary revocation applies from the start of the month of the decision; the other two grounds apply retroactively to the grant date.