Ketevan Abuseridze
Partner, Tax
On 25 February 2026, an amendment was introduced to Order No. 996 of the Minister of Finance of Georgia. According to this amendment, companies are now required to annually submit, through a declaration, information on international controlled transactions.
This requirement applies to transactions carried out with non-resident related parties or residents of offshore jurisdictions, including, for example: the supply or purchase of goods and services, the granting or receiving of loans, royalty payments, and other similar transactions.
The obligation to submit such information applies only to companies whose total volume of international controlled transactions during the previous calendar year exceeds GEL 500,000. The total amount of such transactions includes both remunerated and non-remunerated transactions calculated at market value, as well as outstanding receivables and payables.
The declaration must include the following information:
Companies subject to the so-called Estonian model of profit taxation will report this information in the March monthly profit tax declaration, reflecting data from the previous calendar year. Other companies will submit the information in their annual profit tax declaration. This obligation applies to reporting periods starting from 2025.
In addition, the declaration must indicate whether the company has prepared transfer pricing documentation related to its controlled transactions. It is important to note that the obligation to prepare such documentation already existed for Georgian companies, and the Revenue Service of Georgia actively monitors compliance in this area.
