Georgia double tax treaties — US, UK, Germany
If you are connected to two countries, both may try to tax your income. A double tax treaty decides which country taxes it and at what rate. Georgia has 58 such treaties. We help you claim treaty relief and prove your residency.
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According to the Ministry of Finance's official list, Georgia has 58 double tax treaties in force — including with every EU country, the UK, Switzerland, Turkey, China, Israel and the UAE. The United States and Russia are not on that list.
If both countries treat you as resident, the treaty resolves it with a sequence of tests: permanent home, centre of vital interests, habitual abode, nationality and, finally, agreement between the two tax authorities.
Withholding rates
| Country | Dividends | Interest and royalties |
|---|---|---|
| United Kingdom (2004, protocol 2010) | 0% (15% on dividends paid out of property income, e.g. by a REIT) | 0% |
| Germany (2006, protocol 2014) | 0% — company holding ≥50% with over €3m invested; 5% — ≥10% with over €100,000; otherwise 10% | 0% |
The United States
Georgia's Ministry of Finance does not list a treaty with the US. However, the IRS states officially that the 1973 US–USSR treaty covers Georgia — a treaty much narrower than modern ones. Also, US citizens are taxed by the US on their worldwide income wherever they live, so Georgian tax residency does not end US tax obligations.
Our services
- Assessing which country taxes you
- Residence certificates and foreign forms
- Reclaiming tax withheld at source
- Resolving dual residency
- Planning tax on dividends, interest and royalties
- Disputes with the Revenue Service
Questions & answers
How many double tax treaties does Georgia have?
58 according to the Ministry of Finance, including with every EU country and the UK.
Is there a US–Georgia tax treaty?
Not on Georgia's list, but the IRS considers the 1973 US–USSR treaty to apply to Georgia. In any case, US citizens are taxed by the US on worldwide income.
How do I use a treaty?
You need a residence certificate from the country where you are resident. The Georgian certificate is issued by the Revenue Service within 30 days.
Legal basis
- Tax Code of Georgia
- Finance Minister Order No. 633 (2011) — double tax relief and residency confirmation
Official texts (in Georgian) — Legislative Herald of Georgia, matsne.gov.ge.
Related practice area: Tax disputes
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