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MINISTRY OF FINANCE OF GEORGIA

Double Taxation Avoidance Treaty

The main purposes of the Treaty on the Avoidance of Double Taxation and the Prevention of Fiscal Evasion are to promote economic cooperation between countries and encourage foreign investments. The text of the treaties concluded by Georgia is based on OECD Model Tax Convention, according to which taxing rights are distributed between treaty partners. Particularly, resident of one Contracting State deriving income from the other Contracting State may be taxed whether in the source state of income or in the country of residence. For the avoidance of double taxation, resident of one Contracting State deriving income from the other Contracting State will be credited against tax in the source state. DTA treaty also regulates issues regarding the prevention of fiscal evasion y means of implementing internationally recognized standards of exchange of information for tax purposes.

“Double Taxation Avoidance” Treaties concluded by Georgia

Currently 58 Treaties on the” Avoidance of Double Taxation and the Prevention of Fiscal Evasion” are in force. See attached treaties:

State Permanent establishment, months Dividends Interest Royalties
Austria(2) 6 months 10%/0% 0% 0%
Azerbaijan 6 months 10% 10% 10%
United Arab Emirates 6 months 0% 0% 0%
Belgium 9 months 5% / 15% 10 % 5% / 10% 
Bulgaria 9 months 10% 10% 10%
United Kingdom 12 months 0% / 15%  0% 0%
Germany 6 months 0% / 5% /10%  0% 0%
Denmark 6 months 0% / 5% / 10%  0% 0%
Spain 6 months 0% / 10% 0% 0%
Estonia 6 months 0% 0% 0%
Turkey 12 months 10% 10% 10%
Turkmenistan 6 months/183 days 10% 10% 10%
India 90 days 10% 10% 10%
Israel 9 months 0/5 5% 0%
Iran 12 months 5% / 10% 10% 5%
Italy 6 months 5% / 10% 0% 0%
Ireland 6 months 0% / 5% /10% 0% 0%
Japan 6 months 5%/10% 5% 0%
Qatar 6 months 0% 0% 0%
Lithuania 9 months 5% / 15% 10% 10%
Latvia 9 months 5%/10%/0% 5% 5%
Luxemburg 6 months 0% / 5% /10% 0% 0%
Malta 6 months 0% 0% 0%
Netherlands 6 months 0% / 5% / 15%  0% 0%
Poland 9 months 5% 5% 5%
Portugal 9 months 5%/10% 10% 5%
Rumania 9 months 8% 10% 5%
Greece 9 months 8% 8% 5%
Singapore 9/183 days 0% 0% 0%
Slovenia 6 months 5% 5% 5%
Armenia 6 months/183 days 5%/10% 10% 5%
France 6 months 0% / 5% / 10% 0% 0%
Uzbekistan 6 months 5% / 15% 10% 10%
Ukraine 12 months 5% / 10% 10% 10%
Hungary 12 months 0% / 5% 0% 0%
Finland 6 months 0% / 5% / 10%  0% 0%
Kazakhstan 6 months 15% 10% 10%
Switzerland 6 months 10%/0% 0% 0%
China 6 months 0%/5%/10% 10% 5%
Czech Republic 6 months 5% / 10% 8% 0% / 5% / 10% 
Slovakia 6 months 0% 5% 5%
Bahrain 6 months 0% 0% 0%
Norway 6 months /183 days 5%/10% 0% 0%
Egypt 6 months/183 days 10% 10% 10%
Serbia 9 months 5%/10% 10% 10%
San Marino 6 months 0% 0% 0%
Kuwait 6 months 0%/5% 0% 10%
Croatia 9 months 5% 5% 5%
Belarus 12 month 5% / 10% 5% 5%
Iceland 6 months 5% / 10% 5% 5%
Cyprus 9 months 0% 0% 0%
Korea 9 months 5%/10% 10%/0% 5%/10%
Liechtenstein 9 months 0% 0% 0%
Moldova 6 months/3 months 5% 5% 5%
Kingdom of Saudi Arabia 6 months 5% / 0% 5% / 0% 5% / 8%
Hong Kong 6 months 5% 5% 5%
Kyrgyz 6 months 5%/10% 0%/5% 5%/10%

Multilateral Tax Convention (MLI)

On June 7, 2017 within the OECD ministerial, Georgia signed a “Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting” (MLI).

The primary purpose of the Multilateral Convention is implement BEPS treaty –related measures, in particular minimum standards under BEPS Action 6 and 14 in treaties for the avoidance of double taxation.

Multilateral instrument will cover and amend respectively 34 out of 58 agreements on the avoidance of double taxation concluded by Georgia.

The Multilateral instrument was ratified by the Parliament of Georgia on December 27, 2018 and the instrument of ratification has been deposited within the OECD secretariat.

See attached text of the Convention:

Application of Double Tax Treaties

Granting of benefits under tax treaties concluded by Georgia is regulated by the Decree of the Minister of Finance N 633 as of December 28, 2011.

See attached Order:

The procedure defined by the agreement on the avoidance of double taxation

The Rule for the Mutual Agreement Procedure defined by the international agreement on the Avoidance of Double Taxation is approved by the Order of the Minister of Finance of Georgia

See attached Rule:  

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