Two statuses that are easy to confuse
Buyers often assume that a Georgian residence permit makes them Georgian residents for tax, or that becoming a tax resident needs a permit. Neither is true. The two statuses are granted by different bodies, under different laws, on different tests, and each can exist without the other. The residence permit is an immigration status, decided by the Public Service Development Agency under the Law on the Legal Status of Aliens. Tax residence is a tax status, defined by Article 34 of the Tax Code and certified by the Revenue Service.
Keeping them apart matters because they answer different questions. The permit answers "may I live here?". Tax residence answers "which country taxes which part of my income, and under which rules?". This page sets the two side by side, explains how the day count works and what tax residence changes for a property owner.
Side by side
| Question | Residence permit | Tax residence |
|---|---|---|
| Who decides | Public Service Development Agency | Follows from the Tax Code; certified by the Revenue Service |
| Main test | A legal ground, such as property worth more than $150,000 | 183 days or more of presence in any continuous 12-month period ending in the tax year |
| Period | 1 year for the property permit, 5 years for the investment permit | Set for each tax year separately |
| Document | A decision and a residence card | A certificate of tax residence, on request |
| What it gives | The right to live in Georgia and enter without a visa | Georgian tax treatment of your income; access to tax treaties |
| Needs the other? | No | No, except for one route for wealthy individuals |
How the 183 days are counted
Article 34 of the Tax Code counts actual presence, and the details matter more than the headline number.
- The window moves. The test looks at any continuous twelve months that end within the tax year, not only at January to December.
- Part of a day is a day. Under Article 34(5), the day you arrive and the day you leave both count.
- Some days abroad count as days in Georgia. Article 34(3) treats time abroad for treatment, leisure, a business trip or study as time in the country, which can surprise someone who assumes a long holiday breaks the count.
- Some days in Georgia do not count. Article 34(4) leaves out time spent in Georgia only for treatment or leisure, in transit, or with diplomatic or international-organisation status.
- Each year stands alone. Residence is decided tax year by tax year; the days behind one year's status cannot be counted again for the following year.
A short example. An owner arrives on 10 March and stays until 20 September, then spends the winter elsewhere. From 10 March to 20 September is 195 days, counting both ends, so the owner is a Georgian tax resident for that calendar year, with or without a permit. If the same owner spends only 150 days in Georgia the following year, the earlier days do not carry over and the status falls away, even though the residence permit is renewed as usual.
To be added by the team: the partner accountant to confirm how Article 34(3) and 34(4) are applied in practice to owners who keep a home abroad, and which evidence of days the Revenue Service accepts.
The four combinations
| Position | Typical person | What to watch |
|---|---|---|
| Permit and tax resident | An owner living in Georgia most of the year | Georgian tax rules on all Georgian-source income; home-country rules on leaving |
| Permit, not tax resident | An owner who spends a few months a year in Georgia | Georgian tax on Georgian income only, as a non-resident; home country remains the tax home |
| Tax resident, no permit | Someone living in Georgia 183 days or more on the visa-free year | Tax status arrives on its own; immigration status still needs planning |
| Neither | An investor who visits briefly and lets the apartment | Rental income taxed in Georgia; the rest at home |
What tax residence changes for a property owner
For property income itself, the rules are largely the same whatever your status. Rent from a residential apartment let for living is taxed at 5% under Article 81(2) when no deductions are claimed, and a gain on the sale of an apartment is taxed at 5% under Article 81(3), with an exemption for an apartment owned more than two years under Article 82. Annual property tax depends on family income and the property, as our property tax guide explains.
Where residence makes a real difference is income from abroad. According to PwC's Worldwide Tax Summaries, last reviewed in September 2026, resident individuals in Georgia are exempt from tax on income that does not have a Georgian source. For someone whose salary, pension or investment income comes from outside the country, that is the reason tax residence attracts attention. It is also the reason to be careful: your home country may still tax you, and leaving its tax system usually has its own conditions.
To be added by the team: the partner accountant to confirm the scope of the foreign-source exemption for resident individuals in the Tax Code, including dividends and interest from abroad and income of individual entrepreneurs.
The other side: your home country
Becoming a Georgian tax resident does not, by itself, end your tax residence anywhere else. Each country applies its own test, and some tax their citizens or former residents for years after they leave. A person can therefore be resident in two countries at once, and that is exactly the situation the tie-breaker rules of a double taxation treaty are written for: they typically look at where you have a permanent home, where your personal and economic ties are closest and where you habitually live. Without a treaty, there is no tie-breaker, and the outcome depends on each country's domestic rules. Before relying on Georgian tax residence, ask an adviser in your home country what it takes to leave its system.
Proving tax residence: the certificate
A foreign bank, a tax authority abroad or a treaty claim may ask you to prove Georgian tax residence. The document for that is a certificate of tax residence from the Revenue Service, requested for a particular year, online through the Revenue Service portal or at a service centre. Georgia has 58 double taxation treaties in force according to the Ministry of Finance, including with Israel, the United Arab Emirates, the United Kingdom, Germany and Turkey; neither the United States nor Russia is among the partners on that list. A treaty decides which country may tax which income when both claim you, and the certificate is how you show Georgia's claim.
Tax residence without 183 days
Article 34(6) of the Tax Code allows a high net worth individual to be granted tax residence under rules set by the Minister of Finance, without the 183-day test. As described by Tbilisi law firms, the rules in force since April 2023 ask for three things together: assets in Georgia worth at least USD 500,000; total assets worth more than GEL 3,000,000 or income of at least GEL 200,000 in each of the last three calendar years; and either a Georgian residence permit or Georgian-source income of at least GEL 25,000 in the previous calendar year. The status is granted for the year in which you apply, and the Revenue Service looks at both the purchase price and the current market value of property.
This is the one place where the two statuses meet: a residence permit is one way to satisfy the third condition. An apartment worth at least USD 500,000 can therefore support both a residence permit and, with the other conditions, this tax route.
To be added by the team: the partner accountant to confirm the current Minister of Finance rules for high net worth individuals, the documents the Revenue Service asks for and the state fee.
Risks and exceptions
- Assuming the permit settles your taxes. It does not; the days do.
- Forgetting the moving window. 183 days can be reached across two calendar years.
- Counting only days in Georgia. Certain days abroad count as presence under Article 34(3).
- Ignoring the home country. A Georgian exemption does not end tax obligations elsewhere.
Frequently asked questions
Does a residence permit make me a Georgian tax resident?
No. Tax residence depends on your days of presence under Article 34 of the Tax Code, or on the special route for high net worth individuals.
Can I be a tax resident without a permit?
Yes. Someone who lives in Georgia for 183 days or more within a continuous twelve months becomes resident for tax without any permit; days spent in Georgia only for treatment or leisure are the exception under Article 34(4).
Do I pay less tax on my apartment as a resident?
Mostly no. The 5% rates on residential rent and on sale gains, and the two-year exemption on sales, apply on the same terms.
How do I prove I am a Georgian tax resident?
Request a certificate of tax residence from the Revenue Service for the year concerned.
If I become a Georgian tax resident, do I stop paying tax at home?
Not automatically. Your home country applies its own rules, and a double taxation treaty, where one exists, decides which country has priority for each kind of income.
Does tax residence help my residence permit?
No. The agency decides the permit on its own ground, such as the property, not on your tax status.
The wider picture of payments, bank accounts and taxes for buyers is in our guide to money and taxes, and the immigration side starts with the residence permit by property.
Sources
- Tax Code of Georgia (Articles 34, 81 and 82), Legislative Herald of Georgia (accessed 13 October 2026)
- Georgia: taxes on personal income, PwC Worldwide Tax Summaries, last reviewed 2 September 2026 (accessed 13 October 2026)
- Georgia: individual residence, PwC Worldwide Tax Summaries, last reviewed 2 September 2026 (accessed 13 October 2026)
- Clarifications from the Georgian tax service on tax residence based on wealth, Revera (accessed 13 October 2026)
- Double taxation treaties, Ministry of Finance of Georgia (accessed 13 October 2026)
- Law of Georgia on the Legal Status of Aliens and Stateless Persons, Legislative Herald of Georgia (accessed 13 October 2026)
Change log
- - Explainer published from Article 34 of the Tax Code, PwC Worldwide Tax Summaries, the Ministry of Finance treaty list and law-firm summaries of the wealthy-individual rules; being reviewed by the partner lawyer and accountant.