Tax resident: a status the Tax Code assigns year by year
A tax resident of Georgia is a natural person whom the Tax Code treats as "a resident of Georgia" for a given tax year, normally because they were actually present in the country for 183 days or more in some continuous 12-month window ending in that year.
The legal basis is Article 34 of the Tax Code, read in the current Georgian text on Matsne (consolidated 15 October 2026). Its operative words are საქართველოს რეზიდენტი, "resident of Georgia". The Code does not call individuals "tax residents" (საგადასახადო რეზიდენტი) at all: that phrase appears only twice, in the rules for multinational groups. "Tax resident" is the everyday name, used on this site, for what the law simply calls residence.
Buyers used to tests of domicile or citizenship will find none in Article 34; domicile is a treaty concept here, for example in the Georgia-UK treaty, Art. 4(1). Owning a flat plays no part in the day test, and a residence permit is a separate immigration status: see temporary residence permit.
Reading Article 34 limb by limb, including the parts most guides skip
Paragraph 2 has two limbs joined by "or". Besides the day test, a person is a resident for the whole year if, during it, they "were abroad in the state service of Georgia". This keeps Georgian diplomats and officials posted abroad inside the Georgian tax net, and shows the test is legal, not just a count of nights.
| Paragraph | Rule in brief | Relevance to a foreign owner |
|---|---|---|
| 34(1) | Covers Georgian citizens, foreign citizens and stateless persons | One test whatever the passport |
| 34(2), first limb | 183 days or more in any continuous 12 calendar months ending in the tax year | The usual way in |
| 34(2), second limb | Abroad in Georgian state service during the year | None |
| 34(6) | Residence may be granted to a person with significant property | The main route without the day count |
| 34(7) | A non-resident is anyone who is not a resident under the article | No non-resident status to apply for |
| 34(8) | Status set per tax period; qualifying days are not reused | Each calendar year stands alone |
Days abroad count as presence only when the trip was "specially" (სპეციალურად) for treatment, leisure, a business trip or study. The article was last amended by Law No 6817 of 14 July 2020, after laws of 2011 and 2017, so the 2026 tax reforms left the 183-day rule untouched. Counting arrival and departure dates is covered in the 183-day rule.
The person "secured by significant property": the Code's name for the wealth route
English sources say "high net worth individual". Article 34(6) says residence "may be granted" to a მნიშვნელოვანი ქონებით უზრუნველყოფილი პირი, literally a "person secured by significant property", under rules set by the Minister of Finance, and defines that person by reference to the Law on the Securities Market. We could not confirm the definition in that law. Note the word "may": this residence comes from a decision, not automatically.
| Condition | Threshold |
|---|---|
| Assets in Georgia | At least USD 500,000, as a GEL equivalent |
| Wealth or income | Total assets over GEL 3,000,000, or GEL 200,000 or more of income in every one of the three previous calendar years |
| Link to Georgia | A residence permit (or Georgian citizen ID), or Georgian-source income of at least GEL 25,000 in the preceding calendar year |
| Period | The year of application only |
Sources disagree on whether the USD 500,000 must be real estate, so we say assets. The file needs purchase documents, a current market valuation (see market value) and bank statements; Revera quotes the Revenue Service: both as of the nearest date before applying. We could not find the official text of the 2023 rules. Per Andersen, a compliant file goes to the Minister within 7 working days; a deficient one gets up to 30 days for corrections, then counts as withdrawn. No source mentions a fee.
The route dates from a 2009 joint order of the Ministers of Finance and Justice; its 2010 successor was repealed by joint order No 206/916 of June 2023. The rules updated in 2023, in force from 15 April 2023, added the USD 500,000 condition and allowed filing through an authorised representative.
What the label changes in the Code, and what it leaves alone
Under Article 80, a resident is taxed on gross income of the calendar year minus deductions (80(1)); a non-resident without a permanent establishment is taxed at source under Article 134 without deductions (80(3)). Two exceptions put a non-resident back on a net basis: selling property (80(4)) and rent from a person who is not a tax agent (80(6)). For a foreign flat owner, residence therefore changes less than many expect; see rental income tax and capital gains tax.
| Point | Resident | Non-resident |
|---|---|---|
| Basis of tax | Income after deductions | At source, no deductions, with exceptions |
| Sale of property, rent from a non-agent | Net basis | Net basis as well |
| Income from outside Georgia | Exempt (82(1)(u)) | The exemption is written for residents |
| Rent from a flat in Georgia | Georgian-source (104(1)(l)) | Georgian-source (104(1)(l)) |
| Certificate of residence | Available for the year | None; no non-residence certificate found |
Tax residence alone does not bring anyone into the funded pension scheme. Under Article 2(7), a ratified tax treaty in force has priority over the Code: someone resident in two countries stays a Georgian resident under Article 34, but for treaty purposes the tie-breaker decides (UK treaty, Art. 4(2): permanent home, centre of vital interests, habitual abode, nationality, mutual agreement). See double taxation.
Where the status shows up on paper: certificate, TIN and bank forms
The document built to state the status is the Revenue Service's certificate of residence. The sample we saw was issued to a company on 6 May 2019 and published by Paragraf.rs; we could not confirm that an individual's certificate looks the same. It has two bilingual pages, a covering letter and the certificate:
- Heading: "რეზიდენტობის ცნობა / Certificate of Residence".
- Fields: Name of Taxpayer, Tax Identification Number.
- Key line: "არის(იყო) საქართველოს რეზიდენტი" / "Is (was) tax resident of GEORGIA" in the named year. Only the English adds "tax".
- Authentication: an ID and barcode, checkable at rs.ge/residence; the certificate says they replace a signature (Tax Code Art. 44(12)).
- Scope: one year; no treaty named.
Under Minister of Finance Order No 633, the request (Form No 4 in the 2011 text) is filed electronically in Georgian and English; a foreign authority's own form can be stamped instead, with a notarised Georgian translation.
Other papers prove nothing. The 9-digit taxpayer number a foreigner gets on registering (Art. 66(6)) says nothing about residence. Banks record each holder's country of tax residence under the OECD Common Reporting Standard. A registry extract and a sale contract have no residence field.
Worked example: testing the wealth route in lari, and two people the day count misleads
A buyer with Georgian assets wants residence without 183 days in the country. The lari equivalent of the dollar test moves with the exchange rate. At the National Bank of Georgia official rate of 2.5979 GEL per USD, valid 20 October 2026:
| Test | Figure |
|---|---|
| USD 500,000 x 2.5979 | GEL 1,298,950 of assets in Georgia |
| Income alternative | GEL 600,000 over three years, none below GEL 200,000 |
| Assets alternative | More than GEL 3,000,000 |
| Link without a permit | GEL 25,000 of Georgian-source income last year |
A permit holder meets the third test through the permit. By contrast, a Georgian diplomat abroad all year is still resident under the second limb of Art. 34(2), while a foreign owner with 182 days in Georgia, and no other qualifying window ending in the year, is not.
Tax resident, permit holder, citizen or treaty resident?
| Term | What it is | Link to tax residence |
|---|---|---|
| Residence permit holder | Immigration status under the Aliens Law | Each exists without the other; a permit meets one wealth-route leg |
| Investment permit holder | Immigration status for USD 300,000 in property or investment, 5 years | Not tax residence; the wealth route needs USD 500,000 and two more tests |
| Georgian citizen | Nationality | Same day test; abroad, a non-resident unless in state service |
| Treaty resident | Residence after the tie-breaker | May point to the other country while Article 34 says Georgia |
For tax, 183 days of presence make you resident; for the IT residence permit, in force since 1 September 2025, absence of 183 days or more in any continuous 12 months ends the permit. Compare tax residency or residence permit; the permits themselves are under investment residence permit and permanent residence permit.
Tax resident, residence certificate and the wealth route in five languages
| Language | Tax resident | Certificate of residence | High net worth individual |
|---|---|---|---|
| Georgian | საგადასახადო რეზიდენტი (Code: საქართველოს რეზიდენტი) | რეზიდენტობის ცნობა | მნიშვნელოვანი ქონებით უზრუნველყოფილი პირი |
| English | tax resident | certificate of residence | high net worth individual |
| Russian | налоговый резидент | справка о налоговом резидентстве | лицо с высоким уровнем дохода и имущества |
| Hebrew | תושב מס | אישור תושבות לצורכי מס | יחיד בעל הון גבוה |
| Arabic | مقيم ضريبي | شهادة الإقامة الضريبية | الفرد ذو الثروة العالية |
The Tax Code and the certificate both write საქართველოს რეზიდენტი; Georgian sale contracts and registry extracts have no residence field.
Misreadings that cost owners money or credibility
- "Buying a flat made me resident." Only the wealth route links residence to assets, and it needs a decision.
- "My taxpayer number or permit proves it." Neither does; the Code counts days.
- Ticking "Georgia" on a bank's CRS form without the days. The claim should rest on 183 days or a wealth-route decision.
- Assuming last year's status carries over. Article 34(8) sets it per tax period.
- Asking for a non-residence certificate. We found none; 34(7) makes non-residence a default.
To be added by the team: scans for the team to add: a redacted certificate of residence issued to an individual (to compare with the 2019 company sample), the rs.ge/residence check screen, and a redacted CRS self-certification form from a Georgian bank. Remove names, taxpayer numbers and barcodes.
Working out your own status for a year
Pick the year
Status is set per calendar year.
List the days
Check every 12-month window ending that year.
Strike the excluded days
Transit, treatment, leisure and diplomatic days in Georgia.
Consider the wealth route
Only if all three thresholds are met.
Check the treaty
See whether another country also claims you.
Request the certificate
Apply through your Revenue Service account.
Frequently asked questions
What is a tax resident of Georgia?
A natural person treated as a resident of Georgia for a year, usually after 183 or more days in any 12 months ending in that year (Art. 34(2)).
Does the Tax Code say "tax resident"?
Not for individuals; Article 34 says "resident of Georgia" (საქართველოს რეზიდენტი).
Does buying property make me a tax resident?
No. Only the wealth route links residence to assets: USD 500,000 in Georgia plus two further tests.
Is every Georgian citizen a tax resident?
No. Citizens face the same day test, unless abroad in Georgian state service.
How long does wealth-route residence last?
The year of application only; it must be requested again each year.
Is there a certificate of non-residence?
We found none (Art. 34(7)).
How is a certificate of residence verified?
With its ID and barcode, at rs.ge/residence.
Has the 183-day rule changed recently?
No. Article 34 was last amended by Law No 6817 of 14 July 2020.
Sources
- Tax Code of Georgia, Arts. 2(7), 34, 66(6), 80, 82(1)(u) and 104(1)(l), Georgian text consolidated 15 October 2026, Matsne (accessed 2 November 2026)
- Law on the Securities Market, Matsne, cited by Art. 34(6)
- High net worth tax residence, Revera, Revenue Service clarifications (accessed 2 November 2026)
- Tax residence for high net worth individuals, Andersen in Georgia, 8 October 2026 (accessed 2 November 2026)
- Tax Newsletter No 4, BDO Georgia, April 2023
- Joint orders on the wealth route, first text and second text, Matsne
- Minister of Finance Order No 633, 2011 text, Matsne
- Sample certificate of residence, Georgia, 6 May 2019, Paragraf.rs (accessed 2 November 2026)
- Official exchange rates, National Bank of Georgia, USD rate valid 20 October 2026 (accessed 2 November 2026)
- Georgia-UK double taxation convention, SI 2004/3325, Art. 4
- Georgia to exchange banking information under the CRS, BM.ge (accessed 2 November 2026)
Change log
- - Glossary entry published from the Tax Code of Georgia, the Law on the Securities Market, Revera, Andersen, BDO Georgia, Minister of Finance Order No 633, joint orders of the Ministers of Finance and Justice, a Paragraf.rs certificate sample, the National Bank of Georgia, the Georgia-UK tax treaty and BM.ge.