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High Net Worth Individual (HNWI) Tax Residency in Georgia: Latest Updates


High Net Worth Individual (HNWI) Tax Residency in Georgia


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Understanding Tax Residency in Georgia: Two Paths


The 183-Day Rule: A Quick Overview


Georgian tax residency includes two primary paths, one of which is the 183-day rule; it means if you spend 183 days or more in Georgia in a 12-month period, you qualify as a tax resident. This rule is quite straightforward and is common in many countries. The days can span parts of two consecutive years as long as they add up to 183 days.


Becoming a tax resident under the 183-day rule means you can enjoy Georgia’s flat personal income tax rate and exemptions on most foreign income. This rule is ideal if you plan to spend significant time in the country. However, there are exceptions for certain groups, such as diplomats and specific international workers.


The HNWI Program: Your Fast Track to Tax Residency


If spending 183 days or more in Georgia isn't part of your plan but you still want to benefit from its tax advantages, the High Net Worth Individual (HNWI) program is your unique opportunity. This program allows individuals with an income over 200,000 GEL (approx. 80,000 USD) or personal assets in excess of 3 Million GEL (approx. 1,200,000 USD) to obtain Georgian tax residency without meeting the 183-day physical presence requirement.


The HNWI program is perfect for digital nomads, international investors, and global business owners. It offers flexibility and significant tax savings with minimal physical presence in Georgia.



Georgia's HNWI Program: A Deep Dive


Who Qualifies? Eligibility Criteria & Required Documents


To qualify for the HNWI program, you must meet one of the following criteria:


  1. Asset-Based Criteria: Own assets worth at least 3 million GEL (approximately $1.2 million). As of April 2023, at least $500,000 of these assets must be in Georgia.

  2. Income-Based Criteria: Have an annual income of at least 200,000 GEL (approximately $80,000) for each of the last three years. Additionally, as of April 2023, you must own assets in Georgia worth at least $500,000.


You also need either a Georgian residence permit or proof of receiving at least 25,000 GEL from a Georgian source in the year before your application.


Documents Required for HNWI Tax Residency Application


To apply for HNWI tax residency in Georgia, you need to submit specific documents. The requirements are the same for both Georgian residents and non-residents.


  • Application Form: Complete the HNWI tax residency application.

  • Identification Document:

  • Georgian citizens/residents: Provide your Georgian ID card or residence permit.

  • Non-residents: Provide your passport, officially translated into Georgian and notarized by a notary public.

  • Proof of Assets: A valuation report from a licensed Georgian appraisal company showing personal assets in Georgia worth more than 500,000 USD. (The requirement for global assets of 3 million GEL has been removed.)

  • Proof of Income (if applicable): If you are applying based on income, provide documents showing an annual income of at least 200,000 GEL for the past 3 years. Foreign bank statements must be officially translated into Georgian and notarized by a notary public.



Benefits of the HNWI Program


Benefits of the HNWI Program: Why Georgia?


Georgia offers several enticing benefits for HNWIs:


  • 20% Flat Personal Income Tax: Simplifies tax planning.

  • 1% Small Business Status Tax: For businesses with an annual turnover of up to 500,000 GEL.

  • No Tax on Foreign Income: Only Georgian-source income is taxed.

  • Strategic Location: At the crossroads of Europe and Asia, ideal for accessing multiple markets.

  • Ease of Doing Business: Georgia ranks high in global ease of doing business indexes. If you are thinking of opening a company in Georgia here is a full guide on How to Register Company (LLC) in Country Georgia.


These benefits make Georgia an attractive destination for high-net-worth individuals looking to optimize their tax liabilities in a stable and welcoming environment.



tax residency georgia application process


The Application Process: Step-by-Step Guide


  1. Pre-application Preparation:

    1. Gather necessary documents (proof of assets, income, residence permit, etc.).

    2. Consult a tax professional to ensure all criteria are met.

  2. Application Submission:

    1. Complete the application form.

    2. Submit documents online or in person at the Georgian Revenue Service.

  3. Review and Approval:

    1. The Revenue Service reviews the application and may request additional information.

    2. Upon approval, you receive a Georgian tax residency certificate.

  4. Post-approval Requirements:

    1. Reapply annually to maintain HNWI status.

    2. Keep all documents up-to-date and be prepared for potential audits.



Timeline for Obtaining HNWI Tax Residency in Georgia


Timeline for Obtaining HNWI Tax Residency in Georgia


Duration of the Process


Obtaining HNWI tax residency in Georgia involves several steps and can take some time. Here’s a simplified breakdown to help you plan:


  1. Document Preparation: This step usually takes about 1-2 months. If you already have a Georgian residence permit or have earned 25,000 GEL from a Georgian source, this can be quicker.

  2. Document Requirements:

    1. You need to gather and prepare all necessary documents, such as proof of income or assets.

    2. Documents must be notarized, apostilled, or legalized, depending on their origin.

    3. Translations into Georgian need to be certified by a Georgia notary.

  3. Application Review: Once your application is submitted to the Georgian Revenue Service (GRS), it typically takes around 3 months for the GRS to review and approve it.


  • Total Time: From start to finish, the entire process usually takes about 5 months.

  • Example: If you start preparing your documents in January. By March, you submit your application to the GRS. After their review, you receive your HNWI tax residency certificate in June. Overall, the process took about 5 months.


Optimal Timing for Application


It’s best to start your application process 90-120 days before the end of the year. This timing helps ensure that your application is processed within the same tax year.


  • Early Applications: If you apply in the early months, you are likely to get your certificate within the same year.

  • Late Applications: If you apply in December, your certificate might be issued in the following year. However, it will still count for the tax year in which you applied.


Example: If you apply for HNWI tax residency for the 2023 tax year in November 2023 and your certificate is issued in February 2024, the certificate will still indicate that you are a tax resident for 2023.



Practical Tips for a Smooth Process in country georgia


Practical Tips for a Smooth Process


  • Plan Ahead: Start early to avoid the rush at the end of the year and ensure your documents are in order.

  • Be Patient: The review process can take a few months, so build this into your timeline.

  • Consult a Professional: Working with a Georgian legal expert can streamline the process and ensure you meet all requirements efficiently.



How HNWI Status Can Complement Virtual Zone & International IT Company Benefits


Georgia offers several attractive tax incentives that can intersect to provide significant benefits for high-net-worth individuals, especially those in the IT sector. Here's how the HNWI program can complement the advantages of Virtual Zone or International IT Company statuses:


Income Qualification for HNWI


If you are an IT professional or entrepreneur operating under Georgia's Virtual Zone or International IT Company status, the income you earn through these entities can help you meet the 200,000 GEL annual income requirement for HNWI status. This is particularly beneficial for:


  • IT Professionals: Those earning a substantial income from software development, consulting, or other IT services.

  • Entrepreneurs: Business owners who generate significant revenue through tech-based enterprises in Georgia.


Tax Optimization Strategies


Combining HNWI status with Virtual Zone or International IT Company status offers a unique opportunity to optimize your taxes. Here’s how you can benefit from both regimes:


  • HNWIs: Enjoy a flat 5% income tax rate on Georgian-sourced income, simplifying your personal tax obligations.

  • Virtual Zone or International IT Companies: Take advantage of reduced or zero corporate income tax and exemption from VAT on certain activities, significantly lowering your business’s tax burden.



HNWI Program in Action


What's Changed & How It Impacts You


As of April 2023, the HNWI program has an additional requirement: ownership of at least $500,000 worth of assets in Georgia. This ensures applicants have a substantial financial presence in the country, aligning with Georgia’s goal of attracting significant foreign investment.


The income proof requirement has also changed. Previously, you needed to show Georgian source income in the year of application. Now, you must demonstrate this for the year before your application, necessitating more advanced planning.


Previous HNWI Program Rules


To qualify for Georgian tax residency under the HNWI program, you had to meet two main criteria:


  1. Prove Your High Net Worth (HNWI) Status:

    1. Option 1: Own assets worth at least 3 million GEL (approx. $1,075,000) anywhere in the world.

    2. Option 2: Have an annual income of at least 200,000 GEL (approx. $71,500) for each of the last three years.

  2. Prove Your Connection to Georgia:

    1. Option 1: Hold a Georgian residence permit (can be obtained through owning property, starting a business, etc.).

    2. Option 2: Earn more than 25,000 GEL from a Georgian source (salary, dividends, etc.).


New HNWI Program Rules After April 15, 2023


The new rules add an extra requirement: at least $500,000 of your wealth must be located in Georgia. Here’s what you need to know:


  1. Prove Your High Net Worth (HNWI) Status After April 15, 2023:

    1. Option 1: Own assets worth at least 3 million GEL, including at least $500,000 of assets in Georgia.

    2. Option 2: Have an annual income of at least 200,000 GEL for the last three years and own at least $500,000 of assets in Georgia.

  2. Prove Your Connection to Georgia:

    1. Option 1: Hold a Georgian residence permit.

    2. Option 2: Earn at least 25,000 GEL from a Georgian source in the year before your application.


These updates make the HNWI program more robust and ensure it attracts genuinely high-net-worth individuals contributing to the Georgian economy.



HNWI Requirements: Assets, Income & Residency


Proving Your High Net Worth: What Counts?


To qualify as a High-Net-Worth Individual (HNWI) in Georgia, you must own assets worth at least 3 million Georgian Lari (GEL) (around $1,075,000) globally and own assets in Georgia valued at 500,000 USD or more. 


Types of Assets That Count:


To qualify under the asset criterion, provide proof of owning assets worth at least 3 million GEL, including:


  • Real Estate: Property deeds and valuation reports.

  • Movable Assets: Vehicles, machinery, etc., with supporting documents.

  • Financial Assets: Bank statements, investment portfolios, bonds, and stocks.

  • Cryptocurrencies: Valuation reports and proof of ownership.

  • Shares in Companies: Publicly and privately held shares, with valuation reports.


Additionally, you must show ownership of at least $500,000 worth of these assets in Georgia. The simplest way to meet this criterion is by transferring funds to a Georgian bank account. If you still don’t have one here is a full guide how to open bank account in Georgia remotely


Don’t forget individual property taxes in Georgia, which is an annual tax based on the estimated market value of your property. In Georgia, property taxes are calculated at a standard rate of 1% of the property's value.


Georgian Income Criterion for HNWI


If you don't have assets worth 3,000,000 GEL or more, you can still qualify for HNWI status if you've earned over 200,000 GEL (approximately $70,000 USD depending on the current exchange rate) annually in each of the last three years. For instance, to apply for Georgia HNWI tax residency in 2024, you'd need to demonstrate you've earned at least 200,000 GEL in 2021, 2022, and 2023. This income can be sourced from either within Georgia or abroad.


Summary of HNWI Criteria


To qualify for HNWI status, you need to fulfill one of these conditions:


  1. Assets: Hold assets worth at least 3 million GEL worldwide AND own assets in Georgia with a minimum value of 500,000 USD.

  2. Income: OR earn at least 200,000 GEL annually for the last three years.


After meeting these criteria, you must fulfill an additional requirement to become an HNWI tax resident in Georgia:


  • Option 1: Hold a Georgian residence permit.

  • Option 2: Hold a Georgian resident ID card.


Ways to Qualify for HNWI Tax Residency


You can qualify for HNWI tax residency by meeting one of these combinations:


  1. Assets + Residence Permit/ID Card: Own assets worth 3 million GEL globally, own assets in Georgia valued at 500,000 USD or more, AND hold a Georgian residence permit or ID card.

  2. Income + Residence Permit/ID Card: Earn 200,000 GEL annually for the last three years AND hold a Georgian residence permit or ID card.

  3. Income + Residence Permit: Earn 200,000 GEL annually for the last three years + Have a Georgian residence permit.


Income Thresholds: Georgian Source vs. Foreign Source


Applicants can also qualify based on income:


  • Georgian Source Income: Income from activities within Georgia, such as salaries, dividends, and business profits.

  • Foreign Source Income: Income earned outside Georgia but can count towards the 200,000 GEL annual income requirement.


Proof of income includes tax returns, salary slips, and bank statements. Distinguishing between Georgian and foreign income is crucial, as only Georgian income is taxed under the HNWI program.


Residence Permit vs. Tax Residency: Key Differences


A residence permit allows you to live and work in Georgia, while tax residency status, specifically under the HNWI program, is primarily about tax obligations.


Residence Permit:

  • Required for long-term stay in Georgia.

  • Can be obtained through property ownership, company registration (LLC or other types of business), or employment.


Tax Residency:

  • Concerns tax obligations and benefits.

  • Can be obtained without a residence permit if certain income and asset criteria are met.

  • Primarily benefits those seeking tax advantages without necessarily living in Georgia full-time.


Feature

Residence Permit

Tax Residency

Basis

Immigration law

Tax law

Purpose

Legal right to live and potentially work in Georgia

Determining tax liability in Georgia

Acquisition

Application and approval process

Automatic after 183 days in a calendar year

Duration

Varies depending on permit type

Whole calendar year once 183-day threshold is met

Rights and obligations

Varies depending on permit type

Paying taxes on Georgian-sourced income

Implications

Access to social services, ability to work

No impact on legal right to reside in Georgia



HNWI Program in Action: Practical Scenarios & Case Studies


Applying for HNWI Tax Residency


Meeting the criteria is just the first step. You must apply to become an HNWI tax resident in Georgia. Without an application, you won’t receive the tax residency certificate, even if you qualify.


For Example:


Giorgi, who is Tbilisi-based entrepreneur, from his tech startup that operates globally earns $300,000 annually. He applies for HNWI tax residency and provides income statements from the past three years and documents that show he owns $800,000 worth of assets in Georgia, including an apartment and bank deposits. His application is approved, allowing him to benefit from Georgia's favorable tax regime without having to meet the 183-day physical presence requirement.


Annual Renewal of HNWI Tax Residency Certificate


The HNWI tax residency certificate is valid for one tax year. To continue being recognized as an HNWI tax resident in subsequent years, you must reapply annually. This means submitting a new application each year. However, renewing your certificate is typically easier than the initial application process. Here’s what you need to know:


  • Prepare Updated Documents: Ensure all your documentation is current and meets the renewal criteria.

  • Submit Your Renewal Application: File your application with the GRS before the current tax year ends.

  • Simplified Process: Since your details are already in the system, the renewal process is often quicker and requires fewer documents.


Family Members: Can They Also Benefit?


Receiving an HNWI tax residency certificate doesn’t automatically extend to your family members. Each family member must apply individually and meet the HNWI criteria to gain tax residency in Georgia.


For instance, a spouse or child can apply for tax residency if they hold assets or receive income that meets the program’s requirements.


Here’s how they can do it:


  • Separate Applications: Each family member must submit their own application to the GRS, including proof of eligibility.

  • Meet the Criteria: They must independently meet the asset or income requirements.

  • Document Submission: Provide all necessary documentation, such as proof of connection to Georgia.


For Example:


Davit and Mariam, a couple residing in Kutaisi, both seek HNWI tax residency. Davit applies based on his annual income, which exceeds 200,000 GEL each year. Mariam, on the other hand, owns property in Tbilisi worth $750,000. They each submit their applications individually, and both receive their tax residency certificates, allowing their family to enjoy the tax benefits.



Remote Applications: Is It Possible?



Applying for HNWI in Georgia remotely


Yes, you can apply remotely. You don't need to travel to Georgia if you meet the income criteria. You can grant Power of Attorney (POA) to a Georgian professional who will handle all the procedures on your behalf. This includes submitting your application, representing you at the Georgian Revenue Service (GRS), and other necessary steps. The certificate will be sent to you by post or electronically once approved.


Steps for Remote Application:


  1. Grant POA: Legalize and notarize the POA document.

  2. Submit Documents: The designated professional submits all required documents.

  3. Application Processing: The professional handles queries or additional requirements from the Revenue Service.

  4. Receive Certificate: The tax residency certificate is issued and sent to you.


This method offers flexibility for those unable to travel to Georgia but still wishing to benefit from its tax advantages.


Potential Tax Savings: Is Georgia Right for You?


Georgia’s tax benefits can result in significant savings, especially for high-income earners and those with substantial foreign investments. The 20% flat tax rate and exemption on foreign income make it an attractive destination for tax planning.


Case Study: A digital entrepreneur earning $500,000 annually from global clients can save significantly by becoming an HNWI in Georgia. With proper tax planning, they might only pay tax on income sourced within Georgia, while their foreign earnings remain untaxed.



Tax Considerations: Treaties & Planning Strategies


Double Taxation Agreements: How They Work for Georgians


Georgia has signed double taxation agreements (DTAs) with 57 countries, preventing the same income from being taxed twice. These treaties allow HNWIs to optimize their tax liabilities by ensuring income is taxed in only one jurisdiction.


Do Double Taxation Treaties Apply to HNWI Tax Residents?


Absolutely, they do. Georgia has signed double taxation agreements (DTAs) with 57 countries. These treaties are designed to prevent you from being taxed twice on the same income. As an HNWI tax resident, you benefit from these treaties just like any other Georgian tax resident.


Benefits of Double Taxation Treaties


If you're an HNWI tax resident in Georgia, these treaties can help you:


  • Avoid Double Taxation: You won’t pay taxes on the same income in both Georgia and the other treaty country.

  • Reduce Withholding Taxes: Lower tax rates on dividends, interest, and royalties in the source country.

  • Gain Tax Credits: Taxes paid in one country can be credited against taxes due in the other.


For example, if you earn income in a country that has a DTA with Georgia, you may be exempt from or receive a reduced rate on withholding taxes in that country.


When Double Taxation Treaties Might Not Help


However, if you are already a tax resident in another country based on the days you spend there, the benefits might be limited. Here's why:


  • Tie-Breaking Rules: Article 4 of DTAs uses criteria like your home, economic connections, and days spent in each country to decide your primary tax residency.

  • Lower Priority for Georgia: Typically, if you spend more days in another country, that country will take priority over Georgia for tax residency.


In such cases, Georgia's HNWI status might not be as beneficial because these tie-breaking rules often favor the country where you spend more time.


Best Scenario for Using HNWI Status


The HNWI tax residency certificate is most advantageous if you are not a tax resident anywhere else but in Georgia. This way, you can fully leverage Georgia’s favorable tax regime without complications from other countries' tax rules.



Important Considerations Before Applying for Georgian HNWI Tax Residency


Working with Tax Professionals: Why It's Crucial


Navigating international tax laws and optimizing tax strategies can be complex. On the recommendation of the International Trade Administration, before doing any business deals, it's a good idea to talk to a lawyer who's allowed to work in Georgia. 


Tax professionals can provide tailored advice, assist with documentation, and help in planning the best strategies for tax efficiency.


Taxation on Georgian Source Income


In Georgia, you are only taxed on income earned from Georgian sources. This applies whether you are a Georgian tax resident or not. So, even if you qualify as an HNWI, only your income from within Georgia will be subject to Georgian taxes.


Key Points:


  • Georgian Source Income: Only income generated from activities within Georgia is taxed by Georgia.

  • Non-Georgian Income: Income earned outside Georgia is not taxed by Georgia, regardless of your tax residency status.


Impact of Georgian Tax Residency on Service Income


If you provide services, becoming a Georgian tax resident could mean that more of your income qualifies as Georgian source income, and thus, becomes taxable in Georgia. This is particularly relevant for those who actively provide services within the country.


What to Watch For:


  • Service Income: If you’re actively working in Georgia, your income may be classified as Georgian source income and be taxable.

  • Consult a Professional: Discuss how your income will be treated with a tax expert to avoid unexpected tax liabilities.


Tax Accounting & Bookkeeping Services in Georgia


Ensuring Compliance: Georgia's distinct tax system necessitates that HNWIs maintain meticulous and compliant accounting records. Whether you're managing local or international income streams, accurate accounting is crucial. Mismanagement can lead to audits, hefty fines, and significant reputational damage.


  • Accurate Record-Keeping: For HNWIs, precise bookkeeping is vital. It ensures that all financial transactions are tracked, which is essential for tax reporting and compliance.

  • Preventing Issues: Missteps in tax filing or bookkeeping can trigger audits and penalties. Keeping accurate records helps prevent these issues and maintains your eligibility for the HNWI benefits.

  • Outsourcing to Experts: Given the complexities of Georgian tax regulations, many HNWIs benefit from outsourcing their tax and accounting responsibilities to seasoned professionals. These experts can navigate local laws efficiently, ensuring compliance and allowing you to focus on your core activities.

  • Expertise in Local Laws: Professionals who specialize in Georgian accounting and tax law can provide invaluable guidance, ensuring you meet all regulatory requirements.

  • Efficiency and Precision: Outsourcing allows you to leverage their expertise for accurate and timely tax filings, reducing the risk of errors and penalties.


Payroll Management: Mastering Georgian Labor & Tax Laws


Payroll Taxes Explained: HNWIs who employ staff in Georgia must understand the intricacies of payroll-related taxes. This includes calculating and paying income tax and social security contributions accurately and on time.


  • Income Tax: Georgian income tax on salaries is typically withheld at the source by the employer. Understanding the exact rates and calculation methods is essential for compliance.

  • Social Security Contributions: Employers are also responsible for calculating and paying social security contributions, which fund various welfare benefits for employees.

  • Adhering to Labor Laws: Payroll management extends beyond taxes. It encompasses adherence to Georgian labor laws, including the correct calculation of overtime pay, benefits, and other mandatory employee entitlements.

  • Overtime and Benefits: Ensure that all payroll processes account for legal requirements regarding overtime, bonuses, and employee benefits, to comply with Georgian labor regulations.

  • Importance of Timely Filings: Late or inaccurate payroll filings can result in significant penalties. Maintaining thorough records and ensuring all filings are submitted on time is crucial for avoiding these fines.

  • Record Keeping: Detailed and organized payroll records are essential to demonstrate compliance and avoid discrepancies during audits.


Making an Informed Decision


Consulting a tax expert before starting your HNWI application is essential, especially if you regularly earn income from providing services. This step ensures you understand all the implications and can make an informed decision about your tax residency status.


By understanding these legal nuances, the Gegidze Agency can assist companies and individuals in ensuring compliance with local and international regulations and in maximizing the benefits of the HNWI program.


Official Government Links & Documents


  • Georgian Revenue Service (GRS):

    • The GRS provides detailed guidelines on tax regulations, applications for tax residency, and ongoing compliance for individuals and businesses.

  • Ministry of Finance of Georgia:

    • Offers insights into the financial policies and tax regulations of Georgia, including updates on tax laws that might affect HNWI status.

  • Public Service Development Agency: 

    • Manages services like issuing residence permits and legal documents, which are crucial for those applying for or renewing HNWI tax residency.

  • Enterprise Georgia:

    • Provides resources and support for business development and investment in Georgia, particularly useful for entrepreneurs looking to benefit from the Virtual Zone or International IT Company statuses.

  • Georgian National Investment Agency:

    • Assists foreign investors with comprehensive information on investment opportunities and legal frameworks, including those for high-net-worth individuals.



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FAQ: Common Questions from HNWIs Answered


What is the HNWI Program in Georgia?

breakdown of its key features:


  • Favorable Tax Rates: HNWIs benefit from a flat 5% income tax rate on Georgian-sourced income. There is no tax on income earned outside of Georgia, making it ideal for those with significant international earnings​.

  • Eligibility: To qualify, you must either own substantial assets or have a high income. Specifically, you need to demonstrate assets in Georgia worth at least 500,000 USD, or an annual income of at least 200,000 GEL (around $75,000) for the past three years.

  • Connection to Georgia: Applicants must show a connection to Georgia by either holding a Georgian residence permit or owning assets worth at least 500,000 USD in Georgia​.

  • Annual Renewal: HNWI status is valid for one year and must be renewed annually by reapplying and providing updated documentation​.

  • Application Process: The process involves submitting detailed documentation proving your income or assets and your connection to Georgia. The application can be managed remotely if needed, through a Power of Attorney (POA)​​.

What is the 183 Day Rule in Georgia?

What is the Criteria for HNWI?

How long does the HNWI application process take?

Can I combine HNWI status with Virtual Zone or International IT Company status?


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