For an established IT business with a team in Georgia, payroll can matter as much as the tax on profits. International Company status brings both into the same planning exercise.
Look at the full cost of running the team
International Company status provides a 5% profit-tax rate and a 5% tax rate on employment income. Dividends paid by an International Company receive the specific dividend exemption in the Tax Code. The benefit can be substantial for a business that employs developers and distributes profits regularly.
Build the comparison from your own figures: expected revenue, developer salaries, contractor costs, profit distributions and the cost of operating in Georgia. A rate on a presentation slide tells you much less than a calculation based on the next twelve months of business.
Match the business to the permitted activities
The permitted list includes defined software, programming and related IT activities. The experience requirement normally calls for at least two years of qualifying activity, supported through the applicant or a qualifying business relationship identified in the government rules.
We examine the work that earned the revenue, the company or group history and the people carrying out the activity in Georgia. Client agreements, project descriptions, employment records and earlier financial statements help demonstrate a functioning business.
Make the application reflect the operation
The company should describe the services it will provide, where the work is done and how the Georgian team is organised. An ownership chart connects the application to the companies and experience on which it relies. Financial records and contracts then support that account.
The application is submitted through the Revenue Service process, with the government granting the status. We bring the corporate information, activity explanation and supporting evidence together and handle the Georgian tax questions arising from the application.
Compare International Company and Virtual Zone treatment
International Company status can be especially relevant where a business has a substantial salary bill. Virtual Zone Person status focuses on qualifying IT income and has a different set of conditions. Compare the work, local team and planned distributions under each regime.
Keep VAT as its own calculation. Apply the place-of-supply and registration rules to the actual services and customers. That produces a useful operating budget, including tax costs that would be missed by looking at profit tax alone.
Keep the evidence current
As the business grows, new contracts, product lines and group charges should remain consistent with the approved activities. We help connect the status with payroll, accounts and the records supporting intercompany prices. That makes the tax treatment easier to explain during a future review.
Compare salary cost, distributions and qualifying activity together
International Company status can materially change the tax calculation for a qualifying IT operation. Model the expected revenue, Georgian payroll, operating costs and distributions. Use the company’s actual work and the conditions in the Government rules to determine which income and payments qualify.
| Item | Ordinary treatment | International Company treatment for qualifying activity |
|---|---|---|
| Profit tax | 15% with the statutory gross-up calculation | 5% under the status provisions |
| Salary income tax | Ordinarily 20% | 5% under the status provisions |
| Dividends | Ordinarily 5% withholding for an individual shareholder | Specific dividend exemption under the status provisions |
| Eligibility | Ordinary company rules | Permitted activity, required experience and approval |
| Operating evidence | Normal company and tax records | Evidence of qualifying activity and operations in Georgia |
| Other obligations | VAT, accounting, payroll and reporting as applicable | Assess these separately alongside the special treatment |
Connect the experience evidence with the applicant
The relevant rules use a two-year qualifying-activity history, including specified circumstances involving a participant enterprise. Prepare an ownership chart and a dated account of the qualifying work. Support it with company records, contracts and financial evidence showing which enterprise performed the activity.
For the Georgian operation, identify the people, functions and expenditure supporting the permitted activity. Keep the development and customer records consistent with the application. A group’s general technology business should be translated into evidence of the precise history and operation on which the applicant relies.
Record the effective dates when a status changes
Keep the approval and effective date with the accounting instructions. If the company changes its activity or seeks innovative startup status, review the interaction between regimes before making the application. The September 2025 amendment provides for termination of International Company status from the following month when innovative startup status is granted. Plan the payroll and company-tax transition from those dates.
Run the numbers for your IT business
Send the company history, ownership structure, a description of the products or services and the planned Georgian salary bill. We can compare the practical tax results and prepare the application.
Request a consultationFrequently asked questions
Why does payroll matter when comparing IT tax regimes?
Salary taxes can be a major operating cost for an IT team. International Company status provides a 5% employment-income tax rate, so the comparison should include salaries as well as profit distributions and VAT.
What shows the required business experience?
Relevant evidence can include earlier client contracts, project records and financial statements. The ownership and company history establish how that experience relates to the Georgian applicant under the government rules.
Legal basis: Tax Code of Georgia, Article 23; Government Resolution No. 619, including the amendment by Resolution No. 420 of 22 September 2025.