EY Georgia Tax & Law Brief for April–June 2026

• On 15 April 2026 and 29 June 2026, legislative acts were published introducing amendments to the Law of Georgia on the Legal Status of Aliens and Stateless Persons.
• Pursuant to the amendments, a new C5 Short-Term Ordinary Visa and a new D6 Immigration Visa have been introduced.
• According to the amendments, a C5 Short-Term Ordinary Visa may be issued to a foreign national entering Georgia for tourism reasons, who, while staying in Georgia, is entitled to carry out activities exclusively for the benefit of a non-resident person, provided that such activities are related to the non-resident person's operations outside Georgia.
• A C5 Short-Term Ordinary Visa is issued for a validity period of five years and entitles its holder to remain in Georgia for up to one year.
• Pursuant to the amendments, a D6 Immigration Visa is issued for a period of one year to a minor who intends to study or is studying at an authorized general education, higher education, or vocational education institution in Georgia. The visa may also be issued to the minor's parent(s)/legal representative(s) and minor sibling(s) until the foreign national reaches the age of majority.
• The provisions relating to a C5 Short-Term Ordinary Visa entered into force upon publication, while the provisions relating to a D6 Immigration Visa will enter into force on 1 September 2026.

The source and date of publication:

Website of the Legislative Herald of Georgia. 15/04/2026 
Website of the Legislative Herald of Georgia. 29/06/2026 

•  On 15 April 2026, the Parliament of Georgia adopted amendments to the Law of Georgia on the Legal Status of Aliens and Stateless Persons and the Law of Georgia on Labour Migration. 
• Pursuant to the amendments, a foreign national is not required to obtain a work authorization if such foreign national:  
  • during a temporary visit to Georgia, conducts a short-term professional activity determined by a resolution of the Government of Georgia, provided that such activity is related to a specific short-term project; 
  • conducts work activities or provides services in Georgia for the benefit of a non-resident employer or a non-resident recipient of services, where such activities are connected with the that non-resident’s operations conducted outside Georgia; 
  • carries out managerial or executive functions within an enterprise, or serves on an audit committee, provided that the relevant company is classified as a Category I, II, or III enterprise in accordance with the asset, revenue, and employee-count criteria established by the Law of Georgia on Accounting, Reporting and Auditing. 
• The amendments entered into force on 15 April 2026. 

The source and date of publication:
Website of the Legislative Herald of Georgia. 15/04/2026  

• On 28 May 2026, the Parliament of Georgia adopted amendments to the Law of Georgia on Tourism, among other related legislative changes.
• Pursuant to the amendments, registration in the registry of tourism service providers has become mandatory for entities carrying out tourism-related activities.
• According to the amendments, the Government of Georgia is required to establish a list of high-risk tourism services, as well as the certification requirements and obligations applicable to the provision of such services.
• The amendments provide that the Government of Georgia shall determine the categories of tourism service providers for which professional liability insurance and/or civil liability insurance will be mandatory.
• Pursuant to the amendments, the provision of high-risk tourism services in violation of the law is subject to a fine ranging from GEL 500 to GEL 6,000.
• The amendments entered into force on 1 June 2026.

The source and date of publication:
Website of the Parliament of Georgia. 20/05/2026 

• On 25 June 2026, the Parliament of Georgia adopted amendments to the Law of Georgia on Arranging Lotteries, Games of Chance and Other Prize Games.
• The amendments introduce new categories of permits for activities involving the international operation of casino games, slot machine games, and totalizator (sports betting) games in a system-electronic form.
• Pursuant to the amendments, a holder of such a new permit will be prohibited from allowing Georgian citizens to participate in gambling and/or prize games organized internationally in a system-electronic form.
• The amendments relating to the new categories of permits entered into force upon publication.

The source and date of publication:
Website of the Parliament of Georgia. 03/07/2026.

• On 15 June 2026, the President of the National Bank of Georgia adopted the Rule on the Issuance of Loans/Bank Credits of up to GEL 1,000,000 by Lending Institutions.
• Pursuant to the Rule, the threshold for unhedged foreign currency loans has been increased from GEL 750,000 to GEL 1,000,000.
• According to the Rule, loans/bank credits of up to GEL 1,000,000 issued by lending institutions shall be denominated in GEL, except where:
  • the borrower's total indebtedness to the same lender exceeds GEL 1,000,000;
  • the borrower is not a citizen of Georgia or a legal entity registered in Georgia;
  • the loan is fully secured by cash funds denominated in the same currency as the loan;
  • the borrower receives its income entirely in the currency of the relevant loan; or
  • the transaction constitutes a refinancing or restructuring in the same currency, provided that the amount of the obligation is not increased.
• The requirements of the Rule also apply to guarantors, except for legal entities and certain other cases expressly provided for by law.
• The Rule also applies to payment obligations arising under bank guarantees and letters of credit, where the relevant amount is repayable to the lending institution in accordance with a payment schedule.
• The Rule entered into force on 1 July 2026.

The source and date of publication: 
Website of the Legislative Herald of Georgia. 15/06/2026 

• On 24 April 2026, the National Bank of Georgia adopted Order No. 96/04 on the Rule on Participation in the Payment System.
• The Rule establishes the principal requirements and criteria that shall be satisfied for participation in the payment system by commercial banks and microbanks registered in Georgia, significant payment service providers, and applicants seeking a banking or microbank license.
• According to the Rule, the National Bank of Georgia shall decide on an entity's participation in the payment system within 60 days of receiving the relevant application.
• The Rule establishes the obligations of entities participating in the payment system, including the requirement to conduct a qualified information security audit and penetration testing at least once per year.
• Pursuant to the Rule, the National Bank of Georgia may apply supervisory measures or impose sanctions on entities that fail to comply with the obligations established under the Rule.
• The Rule entered into force on 24 April 2026.

The source and date of publication: 
Website of the Legislative Herald of Georgia. 24/04/2026 

• On 1 April 2026, the Parliament of Georgia adopted the Law of Georgia on Factoring.
• Pursuant to the Law, factoring is a financial transaction whereby an entrepreneur assigns to a factor its claim (accounts receivable) against a third party arising from a contract for the supply of goods or the provision of services.
• The Law provides for the establishment of a Factoring Registry, in which factoring agreements and related information will be registered.
• The Law envisages the creation of a factoring electronic platform, through which factors will be able to publish their offers, while entrepreneurs will be able to compare different terms and select the most suitable option.
• The Law will enter into force gradually and will enter into full force on 1 January 2027.

The source and date of publication: 
Website of the Legislative Herald of Georgia. 06/04/2026 

• On 5 June 2026, the Government of Georgia adopted amendments to the Ordinance on the Approval of Fees and Fee Rates for the Provision of Services by the Revenue Service.
• The amendments increase the fee payable for the issuance of an Advance Tax Ruling.
• Prior to the entry into force of the amendments, the fee for submitting a request for an Advance Tax Ruling is GEL 10,000. Following the entry into force of the amendments, the fee will increase to GEL 20,000.
• According to the amendments, the reduced fee applicable to individuals, who were tax residents of Georgia during the calendar year preceding the submission of the request, will increase from GEL 5,000 to GEL 10,000.
• The amendments will enter into force on 1 January 2027.

The source and date of publication: 
Website of the Legislative Herald of Georgia. 08/06/2026

• In May and June 2026, Public Decisions No. 142, No. 143, No. 147, and No. 175 of the Minister of Finance of Georgia were published.
• Public Decision No. 142 addresses issues relating to the VAT treatment of certain transactions carried out or supported by the State.
• Public Decision No. 143 concerns the income tax treatment of income derived by an individual from the supply of an asset.
• According to Public Decision No. 143, the provision of residential property carried out by a natural person within the framework of entrepreneurial activities and the provision of property within the hotel infrastructure are excluded from the classification of provision of residential apartment/house for tax purposes.
• Public Decision No. 175 clarifies the content of Public Decision No. 143 according to which a systematic and organised activity is an activity under which a person creates, acquires, or disposes of assets as an independent and principal economic activity for the purpose of generating regular income.
• According to Public Decision No. 175, the mere ownership of residential apartments or houses, their number, the duration of ownership, and their subsequent disposal do not, in themselves, constitute sufficient grounds for classifying an activity as entrepreneurial activity.
• Public Decision No. 147 clarifies the content of Public Decision No. 195 of the Minister of Finance of Georgia dated 7 June 2024, which concerns the VAT treatment of exchange (barter) transactions.
• According to Public Decision No. 147, where mixed consideration (monetary and non-monetary) is provided and, based on the opinion of a qualified valuer or expert, the market value of the property (land plot) received by a person (company) is lower than the transaction price, the transaction price agreed between the parties—rather than the market value—shall be used for determining the VAT taxable amount.
• The public decisions entered into force upon publication.

The source and date of publication: 
Website of the Legislative Herald of Georgia. 15/05/2026.
Website of the Legislative Herald of Georgia. 15/05/2026.
Website of the Legislative Herald of Georgia. 19/05/2026.
Website of the Legislative Herald of Georgia. 10/06/2026.

• On 1 April 2026, the Parliament of Georgia adopted amendments to the Tax Code of Georgia.
• The amendments introduced a new system for determining the excise rates for passenger vehicles classified under commodity code 8703 of the National Commodity Nomenclature of Foreign Economic Activity.
• As a result of the amendments, the excise tax rate for passenger vehicles aged 0 to 6 years (inclusive) is set at GEL 1.50 per each 1 cm³ of engine capacity, while the excise tax rate for passenger vehicles aged more than 6 years is set at GEL 4.50 per each 1 cm³ of engine capacity.
• Pursuant to the amendments, the excise tax rate applicable to left-hand drive hybrid passenger vehicles aged 0 to 6 years (inclusive) is reduced by 60%, whereas the excise tax rate applicable to right-hand drive or converted passenger vehicles is increased threefold.
• According to the amendments, electric passenger vehicles are exempt from excise tax where the vehicle is left-hand drive. In the case of a right-hand drive or converted electric vehicle, a fixed excise tax rate of GEL 3,000 applies.
• The amendments also provide for a number of transitional exemptions. In particular, vehicles in respect of which registration or the issuance of the relevant registration documents was completed prior to the entry into force of the amendments will remain subject to the excise tax rates applicable before the amendments entered into force.
• The amendments entered into force on 2 April 2026.

The source and date of publication: 
Website of the Legislative Herald of Georgia. 01/04/2026.