Double Taxation Avoidance Treaty

The main purposes of the Agreement on the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital are to promote economic cooperation between countries and encourage foreign investments. Beginning from 2008 Georgia has initiated and concluded DTA agreements with its major trade partners. Georgian draft agreement is based on 2008 OECD Model Tax Convention on Income and on Capital, 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 agreement also regulates issues regarding the prevention of fiscal evasion by means of implementing internationally recognized standards of exchange of information for tax purposes.

 

Currently Georgia has 54 active agreements.

Austria *

(in force 01.03.06)

(protocol in force 01.03.13)

 

Ireland

(in force 06.05.10)

 

The Netherlands

(in force 21.02.03)

 

Belgium

(in force 04.05.04)

 

Italy

(in force 19.02.04)

 

Poland

(in force 31.08.06)

 

Bulgaria

(in force 01.07.99)

 

Latvia *

(in force 04.04.05)

(protocol in force 27.11.12)

 

Rumania

(in force 15.05.99)

 

United Kingdom *

(in force 11.10.05)

(protocol in force 17.12.10)

 

Lithuania

(in force 20.07.04)

 

Greece

(in force 20.10.02)

 

Germany *

(in force 21.12.07)

(protocol in force 01.01.15)

 

Luxembourg

(in force 14.12.09)

 

France

(in force 01.06.10)

 

Denmark

(in force 23.12.08)

 

Malta

(in force 19.12.09)

 

Finland

(in force 23.07.08)

 

Estonia *

(in force 27.12.07)

(protocol in force 11.03.11)

 

Czech Republic

(in force 04.05.07)

 

Spain

(in force 01.07.11)

 

Azerbaijan

(in force 06.06.98)

 

Singapore

(in force 28.06.10)

 

Ukraine

(in force 01.04.99)

 

Turkey

(in force 15.02.10)

 

Armenia

(in force 03.07.00)

 

China

(in force 10.11.05)

 

Turkmenistan

(in force 26.01.00)

 

Uzbekistan

(in force 20.10.97)

 

Kazakhstan

(in force 05.07.00)

 

Iran

(in force 14.02.01)

 

Qatar

(in force 11.03.11)

 

The United Arab Emirates

(in force 28.04.11)

 
Sweden

Sweden

(in force 26.07.14)

 

Switzerland Confederation

(in force 07.07.11)

 

The State of Israel

(in force 22.11.11)

 

India

(in force 08.12.11)

 

Hungary

(in force 13.05.12)

 

Slovakia

(in force 29.07.12)

 

Bahrain

(in force 01.08.12)

 

Norway

(in force 23.07.12)

 

Egypt

(in force 20.12.12)

 
 

Serbia

(in force 09.01.13)

 

San Marino

(in force 12.04.13)

 

Slovenia

(in force 25.09.13)

 

Kuwait

(in force 14.04.13)

 

Croatia

(in force 06.12.13)

 
 

Portugal

(in force 18.04.15)

 

Japan

(in force 03.04.92)

 

Belarus

(in force 24.11.15)

 

Iceland

(in force 23.12.15)

 

Cyprus

(in force 04.01.16)

 

Korea

(in force 17.11.16)

 

Liechtenstein

(in force 21.12.2016)

 

* Changes

Sweden

Terms of Agreement

State Permanent establishment, months Dividends Interest(1) Royalties
Austria(2) 6 months 0% / 5% /10% 0% 0%
Azerbaijan 6 months 10% 10% 10%
United Arab Emirates 6 months 0% 0% 0%
Belgium 9 months 5% / 15% 10 % 5% / 10% (3)
Bulgaria 9 months 10% 10% 10%
United Kingdom 12 months 0% / 15% (7) 0% 0%
Germany 6 months 0% / 5% /10% (6) 0% 0%
Denmark 6 months 0% / 5% / 10% (2) 0% 0%
Spain 6 months 0% / 10% 0% 0%
Estonia 9 months 0% 0% 0%
Turkey 12 months 10% 10% 10%
Turkmenistan 6 months 10% 10% 10%
India 90 days 10% 10% 10%
Israel 9 months 5% 15% 0%
Iran 12 months 5% / 10% 10% 5%
Italy 6 months 5% / 10% 0% 0%
Ireland 6 months 0% / 5% /10% 0% 0%
Japan 12 months 15% 0%/10% 0%/10%
Qatar 6 months 0% 0% 0%
Lithuania 9 months 5% / 15% 10% 10%
Latvia 6 months 5% 5% 10%
Luxemburg 6 months 0% / 5% /10% 0% 0%
Malta 6 months 0% 0% 0%
Netherlands 6 months 0% / 5% / 15% (2) 0% 0%
Poland 6 months 10% 10% 10%
Portugal 9 months 5%/10% 10% 5%
Rumania 9 months 8% 10% 5%
Greece 9 months 8% 8% 5%
Singapore 6 months 0% 0% 0%
Slovenia 6 months 5% 5% 5%
Armenia 6 months 5% / 10% 10% 5%
France 6 months 0% / 5% / 10% 0% (5) 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% (2) 0% 0%
Kazakhstan 6 months 15% 10% 10%
Switzerland 6 months 10% 0% 0%
China 6 months 0% / 5% / 10% (2) 10% 5%
Czech Republic 6 months 5% / 10% 8% 0% / 5% / 10% (4)
Slovakia 6 months 0% 5% 5%
Bahrain 6 months 0% 0% 0%
Norway 6 months 5/10% 0% 0%
Egypt 6/183 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%
Belarus12 month5% / 10%5%5%
Iceland6 months5% / 10%5%5%
Cyprus 9 months 0% 0% 0%
Korea9 months5% / 10%10%10%
Liechtenstein9 months0%0%0%

Global Forum on Transparency and Exchange of Information

 

The Global Forum is the premier international body for ensuring the implementation of the internationally agreed standards of transparency and exchange of information in the tax area. The Global Forum now has 134 members, including G20 members and all OECD member countries.

On April 11, 2011 Georgia became a member of the Global Forum on Transparency and Exchange of Information for Tax Purposes On 29 April 2014 Georgia was nominated as a fully-fledged member of the Peer Review Group (PRG) starting in 2015 for the period of three years. The Group carries out an in-depth monitoring and peer reviews of the implementation of the standards of transparency and exchange of information for tax purposes and works on the development of the relevant documentation for a robust, transparent and accelerated process. The PRG consists of 30 Members.

In 2013-2014 experts of the Global Forum carried out Phase I review of Georgian legislation. Based on the aforementioned review, on August 4, 2014 Global Forum published a Report, according to which Georgia’s legal and regulatory framework has been recognized in line with the Global Forum international standards on transparency and exchange of information for tax purposes.

On 11 March 2016 Global Forum approved Phase 2 Peer review report of Georgia. Through the Review of the previous three years’ practice it was established that Georgia’s legislation and practice in the field of tax transparency and exchange of information comply with the international standard (Rating: “largely compliant).

Click here to see the Country compliance summary table.



Administrative Assistance in Tax Matters

 

On June 1, 2011 Georgia joined OECD and Council of Europe (COE) 1988 Convention on Mutual Administrative Assistance in Tax Matters. The primary purpose of this Convention is to ensure the provision of administrative assistance among member states, for the purposes of elimination of tax avoidance and evasion. Currently 87 states have signed to the Convention, including OECD member countries, European Council and financial centers.

Signatories to the Convention are available on the link below

http://www.oecd.org/ctp/exchange-of-tax-information/Status_of_convention.pdf


Additional information on Convention on Mutual Administrative Assistance in Tax Matters is available on the link below
http://www.oecd.org/ctp/exchange-of-tax-information/conventiononmutualadministrativeassistanceintaxmatters.htm

Based on the Convention, Georgia has elaborated model bilateral agreement on “Mutual administrative assistance in tax matters”. Georgia has negotiated and concluded agreements with the following States: the Republic of Armenia, the Republic of Azerbaijan, the Republic of Uzbekistan, Russian Federation, Turkmenistan and Ukraine.


Exchange of Information in Tax Matters

Based on the Model Agreement on “Exchange of Information” Georgia has negotiated and concluded bilateral agreements with the Republic of Belarus and the Republic of Lithuania.

For the conclusion of the Agreements negotiations are held with Latvia, while texts of the agreements have been finalized with Seychelles and Bahamas.

For the conclusion of Memorandum on Automatic Exchange of Information negotiations are held with the Netherlands and Memorandum with Argentina has been signed. “


Mutual Administrative Assistance in Customs Matters

Georgia has negotiated and concluded 17 Agreements on Mutual Administrative Assistance in Customs Matters. These Agreements are based on the 2004 WCO Model Convention.

Agreements are in force with the following states:

 

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