When do you become a Georgian tax resident?
Georgia treats you as tax resident for an entire calendar year once your actual stay reaches 183 days or more within any continuous 12-month window ending in that year (Tax Code, Article 34(2)). Any part of a day counts as a full day, so the days you arrive and leave both count. A residence permit, a flat or a company does not make you resident, and you can become resident without any of them. The law says "183 or more", not "more than 183", and the period is any 12 months ending in the year, not only January to December.
This page works through the rule with dates, shows what residence actually changes for a property owner, how to obtain the certificate and what it costs, and how your home country sees it. How tax residence differs from a residence permit is explained in our page on tax residency and the residence permit.
Article 34, paragraph by paragraph
| Paragraph | Rule | What it means for you |
|---|---|---|
| 34(2) | 183 days or more in any continuous 12 months ending in the tax year | Resident for the entire year |
| 34(3) | Days abroad for treatment, leisure, a business trip or study count as days in Georgia | A holiday abroad does not break your count |
| 34(4) | Days in Georgia as a diplomat, for an international organisation, in transit, or for treatment or leisure do not count | A long holiday in Georgia does not make you resident |
| 34(5) | Any day of presence counts, whatever its length | Arrival and departure days are full days |
| 34(6) | Residence for high net worth individuals under Minister of Finance rules | A route without 183 days, renewed each year |
| 34(6.1) | A person resident nowhere is resident in Georgia on application | Only for Georgian citizens |
| 34(6.2) | The Minister may grant residence to foreign persons in cases he defines | We found no order that uses this power |
| 34(8) | Status is set for each tax period; days that made you resident in one year are not counted again for the next | Days cannot be reused across years |
Counting with real dates
The examples below apply the wording of Article 34 to common patterns. They are our calculations: the Revenue Service has not published worked examples.
| Pattern | Days counted | Result |
|---|---|---|
| Arrive 1 July 2026 and stay to the end of the year | 184 in 2026 | Resident for all of 2026 |
| Arrive 2 July 2026 and stay | 183 in 2026 | Resident for all of 2026 |
| Arrive 3 July 2026 and stay | 182 in 2026 | Not resident for 2026 |
| Arrive 3 July 2026, stay until 2 January 2027 | 184 in the 12 months to 2 January 2027 | Resident for all of 2027 |
| Resident in 2026, leave for good in mid-March 2027 | About 74 in 2027 | Not resident for 2027, because 2026 days cannot be reused |
| Two stays of 100 days, March to June and September to December | 200 in 2026 | Resident for 2026, if the stays are not for leisure |
The fourth line is the one people miss: a person who falls short in the first calendar year can still become resident for the next year as soon as any 12-month window ending in it reaches 183 days. How the Revenue Service applies paragraph 8 when a window straddles two years has not been published, so treat the last two lines as a reading of the text.
To be added by the team: our accountant to confirm how the Revenue Service applies Article 34(8) to a 12-month window that straddles two tax years, and which evidence of the purpose of a stay it asks for.
Keeping evidence of your days
No official instruction explains how the Revenue Service checks days, and advisers report that it compares applications with border-crossing records. Two practical points follow. First, your passport stamps or entry records are the backbone of any claim, so keep copies of tickets and boarding passes. Second, because days spent in Georgia "for treatment or leisure" do not count, a person who wants residence should be able to show that the stay was not a holiday: a long-term rental contract in their name, utility bills, a Georgian bank account in use, work or business activity in Georgia, or a child's school enrolment. We found no published rule on who must prove the purpose of a stay.
What residence changes, and what it does not
| Income | Resident | Non-resident |
|---|---|---|
| Rent from a Georgian flat let for living | 5% | 5% |
| Gain on selling a Georgian flat | 5%, or exempt after more than 2 years | Same |
| Dividends and interest from Georgian payers | 5% at source | 5% at source |
| Salary, pension, rent, dividends or interest from abroad | Exempt (Article 82(1)(u)) | Outside Georgian tax |
| Annual return | Before 1 April, for income not taxed at source | Before 1 April, for Georgian income not taxed at source |
| Sale of a property | Return by the 15th of the next month | Same |
| Residence certificate for a treaty or a bank | Available | Not available |
For a property owner, the Georgian tax bill is usually the same either way. Georgian rent and gains are taxed at the same rates, and foreign income is not taxed in Georgia whether you are resident or not. The real value of residence is the certificate: proof, for your home country and for treaty purposes, that Georgia is where you are resident. Residence also does not bring you into the funded pension scheme, which covers Georgian citizens and holders of a permanent residence permit.
The residence certificate: procedure and fees
- Apply electronically through your Revenue Service account, with your name and address in Georgian and in English (Minister of Finance Order No 633, Article 5).
- Choose the speed: free in 20 working days, GEL 50 in 5 working days or GEL 100 in 1 working day (Government Resolution No 96, as consolidated on 6 July 2026).
- The certificate covers one tax year, and advisers and the Revenue Service's own notes say it can be requested only for the year in which you apply.
- If your home tax authority uses its own form, attach it with a notarised Georgian translation; the Revenue Service signs and stamps it.
- Ask the receiving authority whether it wants an apostille; Georgia is a party to the Apostille Convention.
We found no service that certifies non-residence. If you will need a certificate for a given year, plan the application for the moment you have passed 183 days in that year.
When two countries claim you: the treaty tie-breaker
Becoming resident in Georgia does not end residence elsewhere. Where both countries treat you as resident and they have a tax treaty, the treaty decides. The Georgia-United Kingdom treaty, typical of Georgia's 58 treaties, applies these tests in order (Article 4(2)):
- where you have a permanent home available to you;
- if you have a home in both, where your personal and economic relations are closer, your centre of vital interests;
- if that cannot be decided, where you have a habitual abode;
- then your nationality;
- and finally agreement between the two tax authorities.
Some treaty partners question whether a person taxed only on local income is "liable to tax" in the sense of the treaty, which matters because Georgia does not tax its residents' foreign income. We found no official position on this for Georgia, so ask a home-country adviser before relying on the tie-breaker. Russia has no treaty with Georgia; the United States is not on the Ministry of Finance list, although the US Internal Revenue Service still applies the narrow 1973 treaty with the Soviet Union to Georgia.
How four home countries see it
- United States. Citizens are taxed on worldwide income wherever they live. The foreign earned income exclusion is up to USD 132,900 for 2026, for someone abroad for 330 full days in 12 months or a bona fide resident abroad; Georgian residence does not end US filing.
- United Kingdom. The statutory residence test decides; for example, someone resident in the UK in one of the 3 previous tax years is automatically non-resident with fewer than 16 days in the UK.
- Russia. Residence is 183 days in Russia in 12 consecutive months, with status fixed for the calendar year; without a treaty, a Georgian certificate has no treaty effect there.
- Israel. Residence follows the centre of life, with presumptions at 183 days in a year, or 30 days in a year and 425 days over 3 years; the Georgia-Israel treaty provides a tie-breaker.
Our page on double taxation treaties lists every partner country.
Residence without 183 days
For people who cannot spend half the year in Georgia, the high net worth route under Article 34(6) is the only practical alternative. The current rules are set by Minister of Finance Order No 60 of 1 March 2023, in force since 15 April 2023. The application is made online and, according to advisers, forwarded by the Revenue Service to the Minister within 7 working days; one firm reports decisions within about 7 weeks. The status, like the 183-day status, is granted one year at a time. The conditions are set out in our residence comparison.
Leaving Georgia
We found no exit tax on individuals in the Tax Code and no procedure to deregister as a resident. Status simply follows the count for each year: once you no longer reach 183 days in a 12-month window ending in a year, you are a non-resident for that year. Rent and gains from a flat you keep in Georgia are taxed in Georgia as before, and you file before 1 April for any Georgian income that was not taxed at source.
Claims you will read, checked
| Claim | What the law says |
|---|---|
| "You need more than 183 days" | 183 days or more is enough |
| "Only January to December counts" | Any 12 months ending in the tax year |
| "Residents pay tax on worldwide income" | Foreign-source income of resident individuals is exempt |
| "A residence permit makes you tax resident" | Only actual days count |
| "The return is due on 1 April" | The law says before 1 April, so the last day is 31 March |
Establishing residence, step by step
Plan the days
Count from your arrival date, including arrival and departure days.
Live, not holiday
Rental contract, bank account and local activity.
Keep travel records
Tickets and boarding passes for every crossing.
Apply for the certificate
Online, once you have passed 183 days in the year.
Settle the home side
Check your home country's own test before you rely on Georgia.
Risks and exceptions
- Holiday days. Stays for leisure in Georgia do not count.
- Dual residence. Your home country may still treat you as resident.
- No treaty. Without one, there is no tie-breaker.
- Timing the certificate. It covers one year at a time.
- Advice that misreads the law. Check the article, not the summary.
Frequently asked questions
How many days do I need for Georgian tax residence?
183 days or more in any 12 months ending in the tax year.
Do arrival and departure days count?
Yes, any part of a day counts as a day.
Does buying a flat make me tax resident?
No, only days of actual stay count.
Is foreign income taxed if I am resident?
No, resident individuals are exempt on foreign-source income.
How much does the residence certificate cost?
Free in 20 working days, GEL 50 in 5 or GEL 100 in 1.
Can I get a certificate for last year?
Advisers and Revenue Service notes say only for the year of application.
Is there an exit tax when I leave?
We found none for individuals.
Do holidays abroad break the count?
No, days abroad for leisure, treatment, business or study count as days in Georgia.
Sources
- Tax Code of Georgia, Article 34 and others, Legislative Herald of Georgia (accessed 20 October 2026)
- Government Resolution No 96 on Revenue Service fees, consolidated 6 July 2026, Legislative Herald of Georgia (accessed 20 October 2026)
- Minister of Finance Order No 633 on treaty relief and residence certificates, Revenue Service of Georgia (accessed 20 October 2026)
- Georgia: taxes on personal income, PwC Worldwide Tax Summaries, reviewed 2 September 2026 (accessed 20 October 2026)
- Georgia: tax administration, PwC Worldwide Tax Summaries, reviewed 2 September 2026 (accessed 20 October 2026)
- Law of Georgia on Funded Pensions, Legislative Herald of Georgia (accessed 20 October 2026)
- Double Taxation Relief (Georgia) Order 2004, UK legislation (accessed 20 October 2026)
- Double taxation avoidance treaties, Ministry of Finance of Georgia (accessed 20 October 2026)
- Alternative tax residence certificates, REVERA, 30 March 2026 (accessed 20 October 2026)
- Tax residency in Georgia, Andersen Georgia, 2 September 2026 (accessed 20 October 2026)
- Foreign earned income exclusion, Internal Revenue Service (accessed 20 October 2026)
- Statutory residence test guidance, HM Revenue and Customs, updated 11 June 2026 (accessed 20 October 2026)
- 183 days under the Russian Tax Code, ConsultantPlus (accessed 20 October 2026)
- Israel: individual residence, PwC Worldwide Tax Summaries (accessed 20 October 2026)
Change log
- - Explainer published from Tax Code Article 34, the Revenue Service fee resolution and certificate order, the Georgia-UK treaty and official home-country guidance.