Aparthotel in Georgia: a hotel room you own, not a flat in law

Aparthotel: a sales word for hotel rooms sold one by one

An aparthotel (აპარტოტელი) is a building run as a hotel whose rooms or small apartments are sold to individual owners and let to guests by an operator; Georgian law does not use the word and treats each unit as a "hotel room/apartment" inside a hotel.

Government Resolution No 279 of 23 June 2015 (text on Matsne) defines a hotel room/apartment (სასტუმრო ნომერი/აპარტამენტი) as an isolated area in a hotel intended for receiving or accommodating a person, for any purpose, on a short- or long-term basis (Rules Art. 1(4)(ბ)). The Tax Code builds a special regime on it (Art. 26-1), and Public Ruling No 143 of 14 May 2026 decides how its sale is taxed.

In Batumi the word describes ownership: many private buyers each hold one registered unit, and one operator lets them all. The business model and revenue splits are in our guide to aparthotel units in Batumi.

The words Georgian law uses instead

None of აპარტოტელი, აპარტჰოტელი or აპარტ-სასტუმრო appears in the Tax Code, the Law on Tourism, the Public Registry law or Resolutions No 279 and 315. Binding papers use these terms.

Under Res. 279 Rules Art. 1(2), the enterprise must also ensure, through a paid lease, right of use, management, trust, mediation or similar contract with each buyer, that the rooms serve as hotel rooms. The sale contract therefore usually arrives with an operating contract.

Tourist-enterprise status and the 30% hotel-room rule

The Revenue Service grants the status hotel by hotel (Tax Code Art. 26-1(3)). Once the hotel is built, Res. 279 Art. 3 imposes two duties. At least 30% of the building's total area must be hotel rooms/apartments in the construction design documents, in every municipality. And within 10 calendar years of commissioning, VAT-taxable hotel turnover must at least match the VAT-exempt turnover from selling hotel assets (Tax Code Art. 26-1(2)(ბ) first divides it by 1.18).

Letters follow the Georgian text; the English translation labels the free-stay rule 82(1)(z6). We found no public list of status holders; ask for the decision in writing. More under rental income tax.

Registry purpose and Public Ruling No 143: is the unit a flat?

The registry follows the building's papers. Under the Law on the Public Registry (text on Matsne), a unit is registered on its title and construction documents, and on completion on the commissioning document (Art. 15-6(1)). A change of purpose needs such documents or a legalisation act, or else a project agreed with the permit authority (Art. 15-6(7)). The applicant's own statement counts only when neither these documents nor the agency's records establish the purpose (Art. 15-6(8)). Resolution No 315 has no hotel category, so a hotel room most likely sits under non-residential "others"; that is our reading, not confirmed registry practice.

The Ministry of Finance looks at actual use. Public Ruling No 143 (text on Matsne) treats a flat or house as residential only if all four tests are met: (ა) an independent, registered unit; (ბ) meant for living by status and purpose; (გ) basic utilities, actual or possible; (დ) not an inseparable part of an object with no residential purpose. An aparthotel room usually fails the fourth; the registry record matters, but actual function decides.

Its key sentence reads: "სასტუმროს ნომერი, როგორც წესი, წარმოადგენს სასტუმროს ინფრასტრუქტურის ნაწილს, გამოიყენება დროებითი განთავსებისთვის, ფუნქციონირებს მხოლოდ სასტუმროს სისტემის ფარგლებში, რის გამოც, იგი არ განიხილება საცხოვრებელ ბინად, მიიჩნევა სხვა აქტივად". In English: a hotel room, as a rule, is part of the hotel's infrastructure, serves temporary accommodation and works only within the hotel system, so it is another asset, not a residential flat.

The ruling covers only income tax when an individual sells. For a hotel room that means no 5% rate (Art. 81(3)) and no flat exemption after 2 years (Art. 82(1)(ვ.ა)). The general 20% applies (Art. 81(1)), and the other-asset relief (Art. 82(1)(ვ.გ)) is lost while the room is let through the hotel, unless 2 years have passed since that use ended. We could not confirm what the version of 8 June 2026 changed. See capital gains tax.

Stars, time-share and zoning under tourism law

The Law of Georgia on Tourism, Law No 3969, was adopted on 15 December 2023; its latest version is dated 28 May 2026 (text on Matsne). It has no hotel classification, no star system and no accommodation licence. Stars are private: Hotelstars Union lists a Tbilisi contact, HORECA - Hotel Star Georgia. How many Batumi aparthotels hold a rating, we could not confirm.

Time-share contracts under the same law (Art. 2(ლ)) must be registered in the Public Registry from 1 June 2027, and a registered contract survives a change of the accommodation's owner (Arts. 47 and 51(8)). One owner with personal-use days is not automatically a time-share; have a lawyer read the calendar clause.

Zoning may explain the hotel label. Government Resolution No 261, Art. 13 (text on Matsne), allows hotels but lists no housing in the resort-recreational sub-zone; tying that to any named tower is our inference. Galt & Taggart count branded hotel rooms in Batumi rising from 1,522 in 2019 to 2,966 in 2024.

One unit, four labels: brochure, ss.ge, extract and drawing

• Brochure: "apart-hotel", "investment apartment" or plainly "hotel room". The Wyndham Grand Batumi Gonio investing page says buyers "can purchase a hotel room".
• ss.ge: a "Hotel" (სასტუმრო) property type used for whole hotels and for single rooms. Listing 33168956, a "1 room Hotel" of 42 m² on Sherif Khimshiashvili Avenue asking USD 95,000, calls itself an "Elite apartment". Others file such units under "Flat"; sellers choose.
• Registry extract: the purpose (დანიშნულება) beside area, floor and number (Order No 487, Art. 6(4)(დ)). A 2021 auction notice on Matsne gives a mortgaged unit as "ბლოკი C, სართული 46, სასტუმრო 4640" (block C, floor 46, hotel 4640), cadastral code 05.24.05.237.01.01.4640: სასტუმრო where a flat would read ბინა.
• Measurement drawing: function and category (Res. 315, Art. 2(3)). Its "used area" (გამოყენებული ფართობი, Art. 2(7)) is the floor between the enclosing walls, without walls, columns, shafts or internal stairs, plus any loggia, balcony, terrace or veranda: the same rule as for a flat.

Income flows are under rental pool and property management company.

Worked example: what the legal label does to the numbers

Our illustration. A 40 m² unit costs about USD 76,000, Galt & Taggart's average investment apartment in its October 2025 report Real Estate Trends in Batumi. The developer promises a fixed 10% a year, as Wyndham Grand Batumi Gonio does; one company's offer, not a market yield. Income: USD 7,600.

The payer's status moves yearly income by USD 1,140; the "another asset" label costs USD 1,500 to 2,000 per USD 10,000 of gain (a round base, not a forecast). Have an accountant confirm the second row. Our aparthotel versus apartment comparison runs the income side in full.

Aparthotel, hotel room, branded residence or time-share?

See also living area and commercial space.

Aparthotel in Georgian, Russian, Hebrew and Arabic

A Georgian sale contract should copy the registry wording, სასტუმრო with the unit number and cadastral code, or the Res. 279 phrase სასტუმრო ნომერი/აპარტამენტი; აპარტოტელი carries no legal meaning there.

Mistakes buyers make with the word aparthotel

• Reading "apartment" as a flat in law. Building documents decide the purpose.
• Planning the exit on flat rules. As another asset, a hotel room gets neither the 5% rate nor the 2-year flat exemption.
• Assuming 5% on income. The payer needs tourist-enterprise status.
• Trusting advertised stars. Georgian law has no hotel classification.
• Signing the sale without the operating contract. A VAT-free resale depends on the buyer taking it over.

Checking what an aparthotel unit is in law

1. Order the extract

   Look for სასტუმრო or ბინა and the purpose line.

2. Ask for the building's documents

   Permit and commissioning act fix the purpose.

3. Request the status decision

   Revenue Service, tourist enterprise, for this hotel.

4. Read the operating contract

   Type, term, owner days and resale terms.

5. Check any star claim

   Ask for the rating certificate.

6. Model the exit

   Sale gain as another asset, with an accountant.

Frequently asked questions

Is aparthotel a legal term in Georgia?

No. The law speaks of a hotel room/apartment (Res. 279) and a tourist enterprise (Tax Code Art. 26-1).

Is an aparthotel unit a flat when sold?

Usually not. Public Ruling No 143 treats a hotel room as another asset, under the general 20% rule.

What decides the registered purpose?

The construction documents and commissioning act (Law on the Public Registry, Art. 15-6).

Can a hotel unit be re-registered as a flat?

Only on documents such as an agreed change-of-purpose project; ask a lawyer.

How much of the hotel must be hotel rooms?

At least 30% of the building's total area, designated in the construction design, under Res. 279, Art. 3.

Who awards hotel stars in Georgia?

No state body; private schemes such as Hotelstars Union.

Can a hotel unit carry a bank mortgage?

Yes. A 2021 auction notice shows one registered as სასტუმრო.

Can a hotel unit support a residence permit?

A hotel room sold as a unit can count; see the $150,000 threshold.

Sources

1. Government Resolution No 279, 23 June 2015, Matsne (accessed 2 November 2026)
2. Tax Code of Georgia, version of 30 September 2026, Matsne
3. Public Ruling No 143, Minister of Finance, 14 May 2026
4. Law on the Public Registry, Art. 15-6
5. Government Resolution No 315 and Order No 487, Matsne
6. Law of Georgia on Tourism, version of 28 May 2026
7. Government Resolution No 261, Art. 13, Matsne
8. Auction notice, hotel unit 4640, Matsne, 3 December 2021
9. Hotelstars Union, Georgia
10. ss.ge listing 33168956 (accessed 2 November 2026)
11. Investing, Wyndham Grand Batumi Gonio (accessed 2 November 2026)
12. Tourism in Ajara, Galt & Taggart, October 2025
13. Real Estate Trends in Batumi, Galt & Taggart, October 2025

Change log

• 2 November 2026 - Glossary entry published from Government Resolutions No 279, 315 and 261, the Tax Code of Georgia, Public Ruling No 143, the Law on the Public Registry, Order No 487, the Law of Georgia on Tourism, Hotelstars Union, ss.ge, Wyndham Grand Batumi Gonio and Galt & Taggart.