Georgia: Georgian virtual zone entities offer new opportunities for IT companies

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Georgia: Georgian virtual zone entities offer new opportunities for IT companies

intl-updates-small.jpg

Georgia is becoming an increasingly popular jurisdiction for doing business both domestically and internationally. The attractive factors include the country's top ranks in international ratings on ease of starting and maintaining a business, as well as the fact that Georgia has proven itself to be a corruption-free destination. Additionally, due to a number of benefits – such as the absence of currency control rules, the free inflow and outflow of foreign capital, the comparatively low cost of services, as well as the stability of banking system – Georgia constitutes an attractive non-EU hub for structuring an international business. Of further importance is the fact that a foreign investor may enjoy all respective benefits of doing business in or via Georgia without the necessity to stay or come to Georgia. Worth noting is also that Georgia has not yet committed to the global automatic exchange of financial account information and common reporting standard.

One of the benefits provided by the Georgian tax legislation for both the local and foreign IT business sector is a special status company. The so-called "virtual zone entity" (introduced by the Georgian Tax Code) is a legal entity that performs information technology activities and one that has been granted a special status by the Georgian tax authorities. Profit generated by a virtual zone entity (VZE) from the supply of information technology services outside Georgia is exempted from taxation in Georgia.

Some key features of the Georgian VZE include:

  • The income of a VZE is exempt from VAT (18%) and corporate income tax (15%) if the company provides its services to foreign customers located outside Georgia;

  • In the case of dividends' payment (to a physical person or non-resident legal entity shareholder), the only Georgian tax on dividends payable is rated at 5% and is paid by the company to the state budget at the moment of the dividends' payment. Dividends distributed in Georgia to a Georgian shareholder will not be included in the taxable base of such a person. If dividends are paid to a foreign shareholder, then the taxation of such a shareholder in the country of its tax residency shall be analysed with the consideration of provisions of the double tax treaty of the relevant country with Georgia (if any). However, if income of a VZE is not distributed in the form of dividends, but in another manner prescribed by law, then the 5% withholding tax in Georgia will not be paid and, accordingly, there will be no taxation in Georgia;

  • The director of the VZE can be either a local or foreign individual who can be physically located either in Georgia or abroad and can manage the company's account by means of distance banking; and

  • There is no requirement to hold employed staff in Georgia, except for the company's director, who shall be appointed at the point of the company's state registration.

The Georgian legislation does not clearly define what exact activities fall under the definition of the "information technologies activities" for the company to be granted the status of a VZE. However, according to the official website of the Ministry of Finance of Georgia, it is considered to include the "process of research, development, support, design, production and implementation of computer and information systems; as a result, various software products are in place". Thus, a conclusion can be made based on such a definition that any web-based product/service produced and delivered by a Georgian VZE can be considered an "information technologies activity", provided that such an entity performs research, development, support, design activities and is the owner of IP rights for the relevant product.

As a result, the Georgian VZE is becoming a new interesting solution for international IT businesses focused on foreign clients.

pushkaryova.jpg

Anna Pushkaryova (anna.pushkaryova@eurofast.eu)

Eurofast Georgia

Tel: +995 595 100 517

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

The president’s tariff regime has already caused misery for taxpayers. Losing at the Supreme Court would mean it was all for nothing
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
Identifying who will bear the costs and concerns around confidentiality are issues yet to be resolved, advisers say
As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic
The president described it as ‘one of the most important cases in the history of our country’; in other news, Portugal established a VAT group regime
Clients are facing increased TP audit scrutiny in Hungary. DLA Piper Hungary is therefore using AI and advanced analytics to augment its advice, the firm’s head of TP says
Simpson Thacher & Bartlett and MinterEllisonRuddWatts were among the firms that advised on the deal
AI will mean fewer entry-level roles in tax but also the emergence of new jobs, according to tax expert Isabella Barreto
As World Tax unveils its much-anticipated rankings for 2026, we focus on standout performances by PwC, KPMG and Deloitte across the Asia-Pacific region
The partnership model was looking antiquated even before the UK chancellor’s expected tax raid on LLPs was revealed. An additional tax burden may finally kill it off
Gift this article