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Learn moreSmall Business, Virtual Zone and International Company regimes can offer substantial benefits—but only when the company’s contracts, people and operations match the legal requirements.
Georgia offers several preferential tax regimes for technology professionals and companies. The best-known options are Small Business Status, Virtual Zone Person status and International Company status.
No status makes every type of IT income automatically eligible for preferential treatment. The result depends on the services provided, where the work is performed, who creates the software, how the contracts are drafted, where the customer is located and how profits are distributed.
The regimes are designed for different legal forms and business models. Comparing rates without checking eligibility can produce the wrong result.
| Regime | Intended for | Principal benefit |
|---|---|---|
| Small Business | Individual entrepreneurs | 1% income tax on qualifying turnover |
| Virtual Zone Person | Georgian legal entities creating IT products in Georgia for foreign customers | Profit-tax exemption for qualifying profit |
| International Company | Established Georgian enterprises conducting permitted activities in Georgia | 5% profit tax, 5% employee income tax and 0% dividend withholding |
Small Business Status may be granted to an entrepreneur natural person registered in Georgia. Qualifying Georgian-source income is generally taxed at 1%.
The status may be revoked if gross income exceeds GEL 500,000 in each of two consecutive calendar years.
Not every payment received by an individual entrepreneur qualifies for the 1% regime. Georgian legislation identifies prohibited activities and categories of income that remain outside the special treatment.
The classification of the actual work is particularly important. Software development, technical implementation and professional consulting may receive different treatment even when the parties informally describe all of them as “IT services.”
The status normally becomes effective from the month following the month in which it is granted. Earlier income should be analysed separately.
Virtual Zone Person status is available to a Georgian legal entity engaged in qualifying information-technology activities. The definition focuses on studying, supporting, developing, designing, producing and implementing computer information systems that result in software products.
The principal benefit is an exemption from Georgian profit tax for qualifying profit earned from supplying outside Georgia information technologies developed by the Virtual Zone Person.
To apply the benefit, the company should be able to demonstrate that:
A status certificate alone is not enough to prove entitlement to the benefit for every transaction. The company should document where and by whom its products were created.
If all developers work outside Georgia, demonstrating that a product was developed in Georgia may be difficult. If the director personally performs development or service work, the operational role and remuneration should be documented; dividends should not substitute for salary for work actually performed.
VAT, withholding tax on certain non-resident payments, reverse-charge VAT, accounting and reporting obligations may also apply.
For many business-to-business services, the place of supply is where the business customer is established. If the customer is outside Georgia and no exception applies, the service may be treated as supplied outside Georgia—not as a Georgian transaction taxed at 0%.
The result can differ for consumers, electronically supplied services, fixed establishments, licensing, related parties and services used in Georgia.
Domestic taxable supplies are generally subject to 18% VAT. Mandatory registration usually arises when Georgian VAT-taxable transactions exceed GEL 100,000 during any 12 consecutive calendar months. Foreign-client revenue must be classified before calculating the threshold.
International Company status is intended for established Georgian enterprises carrying out activities permitted by Government Ordinance No. 619.
Permitted IT activities include software publishing, computer programming and consulting, computer-facilities management, digital products, website development, hosting, remote maintenance and system administration.
The applicant, a qualifying non-resident enterprise represented by it, or certain majority corporate owners must generally have at least two years of experience in the relevant permitted activity.
The Georgian enterprise must conduct its principal income-generating activity in Georgia and maintain appropriately qualified personnel and adequate operating expenditure in the country.
The company may also reduce taxable distributed profit by qualifying Georgian expenditure, including salaries paid to Georgian citizens and qualifying research, design and experimental-development costs. Each deduction must be documented.
Georgia currently has 58 double-taxation treaties in force. Treaty relief is not automatic: the analysis depends on tax residence, beneficial ownership, permanent establishment, the legal nature of the payment and supporting documents.
Russia is not included in Georgia’s current official list of treaties in force.
For an IT business, tax compliance begins with the contracts. Customer agreements should clearly identify:
The distinction between a service fee and a royalty can affect Georgian withholding tax and treaty treatment. Employee and contractor agreements should contain appropriate intellectual-property provisions.
A remote employee or contractor can create payroll, social-security, labour-law, permanent-establishment or corporate-tax obligations in the country where that person works.
Foreign nationals physically working in Georgia may also need an individual right to work and an appropriate immigration status under the rules applicable from 2026.
Payments for foreign software, licences, cloud services, advertising, consulting and contractor services should be reviewed before payment. They may create withholding-tax, reverse-charge VAT, residence-certificate or transfer-pricing obligations.
An invoice described simply as “software services” may contain legally different elements—licensing, support, development and cloud access—that require separate analysis.
Preferential status does not eliminate routine compliance. Accounting records should reflect the company’s actual activity rather than only the wording used when the business was registered.
The penalty figures in the original 2022 article are no longer current. Under the present Tax Code:
More serious cases may create additional administrative or criminal exposure.
Small Business Status can suit an individual specialist with qualifying income. Virtual Zone Person status may fit a Georgian company genuinely developing software in Georgia for foreign customers. International Company status is designed for a larger or more established operation with sufficient experience, employees and substance.
Before choosing, review:
This publication provides general legal and tax information and does not constitute individual advice. Tax treatment depends on the facts of each transaction. Legislation and administrative practice may change. Legislation checked on 21 October 2026.
JUST Advisors can review your operations and contracts, compare the available regimes, obtain the relevant status and organise ongoing accounting and tax compliance.