New Tax Reality in Georgia: 2026 Amendments Are Now Law

Georgia has formally amended its Tax Code for 2026. The changes were introduced by Law No. 1061-IVМС-XIМП of 12 November 2025 and published in the Official Gazette, giving them full legal force. The scope of the update makes one thing clear: this is policy, not housekeeping.

The amendments eliminate the special trading zone regime, refine the timelines for submitting CbC reports, and extend important tax benefits in agriculture, financial markets, and specific business sectors. VAT exemptions have been broadened and prolonged, while dividend taxation in Georgia now follows a revised set of rules. For businesses planning ahead, these changes aren’t background noise — they set the tone for tax strategy in 2026.

Georgia’s 2026 Tax Code Reset: From Special Zones to One Rulebook

The key amendments to Georgia’s Tax Code for 2026 remove provisions governing the legal status of special trading zones and the market entities operating within them. This move signals a clear shift away from previously favored special tax regimes toward a more unified and standardized approach to taxing businesses. At the same time, the law fine-tunes procedural rules in tax administration related to transfer pricing, specifically Country-by-Country Reporting.

Instead of the previously fixed deadline requiring CbC reports to be filed by 31 December of the relevant year, the amendments introduce a more flexible, internationally aligned approach. Under the new rules, the report must be submitted within 12 months following the end of the taxpayer’s reporting financial year. Less calendar dogma, more real-world logic.

A substantial part of the 2026 amendments focuses on extending tax incentives with clear socio-economic and investment value through the end of December 2027. Lawmakers chose continuity here, preserving tax benefits for income generated through agricultural projects, financial instruments, and selected specialized business initiatives. The idea is straightforward: keep the incentives alive where they still pull economic weight. In particular:

• the personal income tax exemption is extended for individuals engaged in agricultural activities on income arising from the first supply of domestically produced agricultural goods, provided their annual gross income does not exceed GEL 200,000;
• the same income threshold and tax treatment continue to apply to wages earned by such individuals, reinforcing support for small and medium-scale agricultural producers.

Preferential taxation of interest income also remains in place. This applies to interest earned on debt instruments issued by Georgian residents through public placement and listed on a recognized trading platform, as well as to similar interest income received by non-residents, provided it is not connected to a permanent establishment in Georgia.

Further amendments to the 2026 Tax Code extend exemptions for agricultural cooperatives. These cooperatives remain exempt from tax on distributed income derived from the primary turnover of national enterprises, as well as from income generated through internal settlements within the cooperative. In addition, the exemption continues to apply to dividends paid to members of agricultural cooperatives, with the exception of profits arising from specific activities that are explicitly excluded by law.

This isn’t a cosmetic update. It’s a deliberate recalibration—less fragmentation, more alignment, and a longer runway for sectors the state still wants to see grow.

How Georgia’s 2026 Tax Reform Rewires the VAT Rules

Under the updated tax framework, dividends distributed by Georgian resident companies are not subject to taxation and are excluded from the recipient’s aggregate income — provided those dividends are received directly from banks, microfinance institutions, or other licensed creditors. This preferential treatment applies to profits generated in 2023 and all subsequent reporting periods. A quiet but meaningful shift for anyone structuring payouts through financial institutions.

When it comes to indirect taxation, the 2026 reform stretches further. Until 2029, Georgia has extended the VAT exemption with the right to deduct input VAT for real estate transactions and related construction services, as long as the required building permits are in place and the intended use of the property is properly confirmed. This keeps large-scale development and construction projects operating in a predictable tax environment.

The reform also preserves VAT relief for low-value goods imported by individuals for personal use. This exemption remains in force until 2028, maintaining a familiar cushion for private imports crossing Georgia’s customs border.

A notable addition to the Tax Code introduces VAT exemption in Georgia, with full input VAT deduction rights, for transactions involving the supply and import of investment gold. This change aligns Georgia more closely with international tax practice in precious metals and strengthens its position as a jurisdiction open to investment-grade assets.

Taken together, these adjustments don’t just tweak VAT mechanics — they redraw the boundaries of how value, capital, and investment move through the Georgian tax system heading into 2026 and beyond.

Final Word: Georgia’s 2026 Tax Reform Is Not a Footnote

Georgia’s lawmakers are deliberately tightening the rules of the game for investment and taxation. The amendments to the Tax Code enter into force on 1 January 2026, unless specific transitional provisions say otherwise, and from that moment they become mandatory terrain for everyone doing business in the country. These changes aren’t abstract legal theory — they must be baked into planning, forecasting, and day-to-day tax compliance.

What’s been adopted materially reshapes how business and tax planning work for both Georgian residents and foreign investors. Updated transfer pricing rules, extended and refined tax incentives, and revised approaches to dividend taxation and VAT shift the balance of many existing structures. Old models won’t automatically break, but many will quietly become inefficient or risky if left untouched.