Georgia

Transfer Pricing in Georgia

Transfer pricing in Georgia (the country, GE, currency GEL; not the US state) for tax year 2026, under Chapter XVII of the Tax Code (arts. 126 to 129^1) and the Minister of Finance Instruction on international controlled transactions (Order No 423 of 18 December 2013, as amended to Order No 331 of 2 October 2024). Covers related persons and the 50% test, which transactions are controlled (cross-border related parties, any transaction with a resident of a preferential tax country, dealings with a permanent establishment), the Government list of preferential tax countries (Ordinance No 615), the five methods and the CUP preference, the interquartile range and adjustment to the median, services and intangibles, loans treated as capital from 2025, documentation within 30 days of a request, advance pricing agreements, the country-by-country report and its GEL 5,000 fine, and how an adjustment is taxed as distributed profit. Trigger phrases: Georgia transfer pricing, controlled transactions Georgia, arm's length Georgia, offshore list Georgia, TP documentation rs.ge. Out of scope: profit tax generally (ge-corporate-income-tax), withholding and treaties (ge-cross-border), VAT (georgia-vat).