Georgia: special regime for HNWI

Грузия HMNI режимGeorgia has a special regime for High Net Worth Individuals (HNWI). According to the Tax Code of Georgia, high-income individuals can obtain a certificate of tax residency in Georgia without having to stay in the country for 183 days or more and meet other criteria traditionally used in determining tax residency (e.g. center of vital interests). For this purpose HNWI are persons who own assets in the amount of more than 3 000 000 GEL (approximately 975 000 USD) or whose annual income for the last 3 years was more than 200 000 GEL per year (approximately 65 000 USD).

To apply for a tax residence certificate, in addition to meeting the HNWI criteria, a person must also have a Residence permit in Georgia (or Georgian citizenship) or have proof that such person receives income from the territory of Georgia in the amount of 25,000 GEL (approximately 8200 USD) or more in the calendar year in which the application for a tax residence certificate takes place (for example, in 2021).

There are several options for obtaining a Residence permit in Georgia, in this article we will look at the 3 most popular of them (but it is worth to mention that to obtain any permit, a person will need to visit Georgia):

1) Residence permit on the basis of work (Permit for employees)

To obtain this permit, a person must be employed in Georgia with a salary of 5 times the minimum wage (approximately 1500 GEL per month) or own a company registered in Georgia. In both cases, the employer company or the company owned by the person must show 50,000 GEL (approximately 16,500 USD) of income for the previous 12 months prior to the month of applying for a residence permit.

2) A residence permit based on the investment made (Investment residence permit)

To obtain this permit, a person must invest more than 300,000 USD in Georgia (agricultural land is excluded from the investment). In addition to this, it is necessary to have written recommendations from 3 Georgian citizens who are directors of Georgian companies engaged in active business activities.

3) Short – term residence permit (Short-term residency permit)

To obtain this permit, a person must own an asset on the territory of Georgia (for example, an apartment) worth at least 100,000 USD (the assessment must be made by a certified expert).

Applying for a tax residency certificate is free of charge, and the application review takes about 2 months. Submission takes place online via the platform www.rs.ge and for these purposes, the applicant must be registered as a taxpayer.

The value of the assets (more than 3,000,000 GEL) must be confirmed by a qualified auditor. The receipt of an annual income (200,000 GEL per year) can be confirmed by submitting a bank account statement with a bank stamp.

In accordance with the legislation of Georgia, income received by a tax resident of Georgia outside of Georgia is not taxed in Georgia (Article 82 of the Code). Article 104 of the Tax Code of Georgia defines what type of income is considered to be received from a source in Georgia, all other income is automatically considered to be received from abroad and is therefore exempt from the Georgian personal income tax. That is why Georgia is so popular among businessmen as a country for possible relocation and change of tax residency. Read more about alternative countries for relocation in our previous article.

 

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