Russian nationals register more Georgian companies than any other nationality on this site, and the tax question they ask is rarely the one that matters most. Most guides to this move open with a treaty article and a tie-breaker test. We cannot, because the treaty most sites assume exists does not. This guide checks both governments' own published lists directly, then works through what actually governs the move: the 183-day residency test, the remote-worker rule that keeps taxing some income regardless of where you live, and the CFC notification obligations that carry real penalties whether or not any tax is owed.
What a Russian freelancer actually pays, here and there
A Russian IT contractor invoicing 6,000,000 RUB a year, roughly $77,000 at current exchange rates, generally registers as an Individual Predprinimatel (IP) on the simplified taxation system (USN) at the 6% "income" rate. A solo IP without employees can credit fixed insurance contributions in full against the USN bill, with no percentage cap. For 2026, fixed contributions are 57,390 RUB, plus 1% of revenue above 300,000 RUB, a further 57,000 RUB on this income, for total contributions of 114,390 RUB. Because that is smaller than the 360,000 RUB owed at 6%, the whole amount is creditable rather than sitting on top of it, so the real bill lands close to 360,000 RUB, an effective 6% all-in rather than 6% plus a separate contribution layer, a detail several summaries of the USN regime get wrong for a contractor with no staff.
| Russia (IP, USN 6%) | Georgia (Small Business Status) | |
|---|---|---|
| Turnover | 6,000,000 RUB (~$77,000) | Same turnover |
| Tax and contributions, all-in | ~360,000 RUB (~6%) | ~60,000 RUB-equivalent (~1%) |
Georgia's rate is a genuine multiple cheaper even against Russia's already-low domestic option. That comparison is not, however, the reason this guide exists. The reason is what sits underneath it.
Does Georgia's 1% actually apply to your income in the first place
Small Business Status taxes Georgian-source income, and for services that generally means work physically performed in Georgia, not income billed through a Georgian registration while living in Moscow or St. Petersburg. We cover the source-of-income test fully in Georgia's 1% tax and Georgian-source income rules, and it applies to a Russian national exactly as it does to anyone else in this cluster. What changes is what Russia does with the rest of the picture.
What Russia does when you leave
Russian tax residency, under Article 207 of the Tax Code, runs purely on physical presence: 183 days or more in Russia within any rolling 12 consecutive months makes you a tax resident on worldwide income. Fall below that and you become a non-resident, taxed only on Russian-source income, generally at a flat 30%. The count is not tied to citizenship, a residence permit or registered address, and it runs on a rolling basis rather than only at year-end.
Breaking the day count is not the whole story. Federal Law 389-FZ, in force from 1 January 2024, made income paid under an employment contract with a Russian employer count as Russian-source regardless of the employee's tax residency, taxed at the standard 13% or 15% whether or not the person has left. A parallel extension reaching civil-law and freelance contracts delivered through Russian domains or hosting followed from 1 January 2025. A Russian professional who moves to Georgia but keeps invoicing a Russian employer or client under a Russian-law contract can still owe Russian tax on that income, independent of the 183-day test and independent of anything Georgia charges. This is the single most common way a Russian national's Georgian structure quietly fails to do what was expected of it.
A tax treaty between Russia and Georgia was signed on 4 August 1999. Georgia's Parliament ratified it. The Russian Duma never did, so it never entered into force, and it has never applied. We checked both governments' own current lists directly rather than a secondary summary: Georgia's Ministry of Finance publishes a list of 58 double tax treaties in force, and Russia is not on it. Russia's own Ministry of Finance publishes a document on the status of its international tax agreements, and Georgia does not appear on it either. Two governments, two independent official lists, and neither one lists the other, despite a number of sites describing this treaty as active. No treaty means no tie-breaker article if both countries assert a claim on the same income, and no reduced withholding on anything paid between the two.
The missing treaty shapes the CFC question too. Russia's controlled foreign company regime, under Article 25.13 of the Tax Code, makes a Russian tax resident a "controlling person" of a foreign entity above 25% held alone, or 10% where Russian residents together hold more than 50%. A Georgian Individual Entrepreneur has no separate legal personality, so there is no foreign company for the rule to attach to, and the income is reportable as ordinary foreign-source income rather than attributed CFC profit. A Georgian LLC is squarely in scope if the threshold is met, and Russia's position here is notably harsher than most: the "active foreign company" exemption under Article 25.13-1 only applies where Russia has an income tax treaty with the CFC's country of registration, and Georgia is not one. That closes the exemption off entirely, however genuinely active the LLC's business actually is.
Beyond the CFC rules themselves, a Russian resident who controls any foreign entity, IE arrangements aside, carries a notification of participation within three months of the interest arising above 10%, and an annual CFC notification with the personal tax return by 30 April. Under Article 129.6, a missed or inaccurate CFC notification carries a penalty of 500,000 RUB per company, and a missed participation notification a further 50,000 RUB per entity, regardless of whether the CFC has any profit at all. Separately, every Russian citizen remains a currency resident for life, obliged to notify the FNS within a month of opening a foreign account and, depending on status, file an annual report on its movements, though most restrictions ease once you have spent more than 183 days abroad in a year.
None of this is the part clients experience first. Georgian banks apply meaningfully heavier compliance scrutiny to Russian nationals than to most other nationalities, a consequence of the international sanctions regime rather than anything in Georgian tax law itself. Source-of-funds documentation gets checked more closely, transactions resembling a transit through the account draw scrutiny fast, and approval is no longer close to automatic the way it can be for other nationalities covered in business bank account in Georgia. This is a real, practical planning factor, stated plainly rather than glossed over.
The steps, in order
- Count your days carefully against Article 207's rolling 12-month window, not a calendar year, since the 183-day test can be satisfied or broken partway through a year.
- Stop invoicing under a Russian employment contract, or restructure the arrangement, since the 2024 remote-worker rule taxes that specific income as Russian-source regardless of your own residency.
- Register a Georgian Individual Entrepreneur and apply for Small Business Status, either in person or under power of attorney through remote company registration.
- Choose an IE over an LLC unless you have a specific reason not to, since an IE sits outside Russian CFC rules entirely, while an LLC is squarely in scope with no active-company exemption available.
- File the participation notification within three months of any foreign shareholding above 10%, and the annual CFC notification by 30 April, regardless of whether tax is actually owed.
- Notify the FNS within a month of opening a Georgian bank account, since currency-resident status does not end with tax non-residency.
- Prepare clear source-of-funds documentation before the bank visit, given the heavier compliance scrutiny Georgian banks apply to Russian applicants.
Timeline and cost
Georgian registration itself is fast: an Individual Entrepreneur with Small Business Status typically registers within days in person, or two to three weeks under power of attorney. Banking is realistically the slower step for a Russian national specifically, and it is worth budgeting extra time and having a documented source-of-funds story ready before the branch visit rather than after a rejection. The CFC and currency-notification obligations above are not one-time setup tasks. They are recurring, annual, and worth building into the plan from day one.
We'll map out your Article 207 residency position, whether the 2024 remote-worker rule reaches any of your current income, and your CFC and currency-notification obligations if you go the LLC route, before you register anything here.
See what it costs
The verdict for a Russian national
Georgia works with conditions for a Russian national. The tax arithmetic is genuinely favourable even against Russia's own low-tax IP regime, and an Individual Entrepreneur generally sits outside both the CFC rules and most of the legal complexity that makes some other guides in this cluster harder cases. What makes this a conditional yes rather than a clean one is the missing treaty, which removes any tie-breaker if a dispute arises, the remote-worker rule that can keep taxing Russian-employer income regardless of where you live, and the notification obligations and banking scrutiny that are real, practical facts of this specific move.
For the other post-Soviet country with the largest actual population of new arrivals in Georgia, see moving from Ukraine to Georgia. Our full country-by-country guide compares the treaty position and headline trap across every country we cover, and a free consultation is the fastest way to get a straight answer on your specific situation.
Key takeaways
- Count your days against Article 207's rolling 12-month window, not a calendar year, since the test can break partway through a year.
- Stop invoicing under a Russian employment contract before assuming the 2024 remote-worker rule no longer reaches your income.
- Register as an Individual Entrepreneur rather than an LLC unless you have a specific reason to prefer the company structure.
- File the participation and annual CFC notifications on time even where no tax is owed, since the penalties do not scale with tax due.
- Notify the FNS within a month of opening any Georgian bank account, since currency-resident status never lifts for a Russian citizen.
- Bring clear source-of-funds documentation to the bank visit rather than assuming approval will be routine.
Frequently asked questions
Is there a tax treaty between Russia and Georgia?
No. A treaty was signed in 1999, ratified by Georgia's Parliament but never by the Russian Duma, so it never entered into force. Neither government's own current treaty list includes the other.
Why does the missing treaty matter if I am just running a small IE?
Without a treaty there is no tie-breaker article if both countries ever assert a claim on the same income, and no reduced withholding on payments between the two. For a clean, well-documented structure this stays mostly theoretical, but it removes the safety net most other country guides in this cluster can point to.
How is Russian tax residency determined?
Under Article 207 of the Tax Code, purely by physical presence: 183 days or more in Russia within any rolling 12-month period makes you a tax resident, taxed on worldwide income. Fewer days makes you a non-resident, taxed only on Russian-source income, generally at a flat 30%.
Does moving to Georgia stop Russia taxing my income from a Russian employer?
Not automatically. Since 1 January 2024, income under an employment contract with a Russian employer is treated as Russian-source regardless of your tax residency. Civil-law and freelance income delivered through Russian domains or hosting followed under similar rules from 2025.
Do Russian CFC rules reach a Georgian Individual Entrepreneur?
Generally not. Russia's CFC rules attach to foreign entities with separate legal personality. A Georgian IE has none, so there is no entity for the rule to attribute income from.
Do Russian CFC rules reach a Georgian LLC?
Yes, above 25% held alone or 10% where Russian residents together hold over 50%. The usual active-company exemption is unavailable here specifically because it requires a tax treaty between Russia and the CFC's country, and none exists with Georgia.
What happens if I do not file the Russian CFC notification?
The penalty is 500,000 RUB per company for a missed or inaccurate CFC notification, and a further 50,000 RUB per entity for failing to notify participation in a foreign organisation in the first place. Both apply regardless of whether the CFC actually has any profit.
Do I still have to report my Georgian bank account to Russia after I move?
If you remain a Russian citizen, yes. Currency-resident status never lifts regardless of where you live, and you must notify the FNS within a month of opening a foreign account, though most restrictions ease once you have spent more than 183 days abroad in a year.
Why do Georgian banks scrutinise Russian applicants more closely?
It stems from the current international sanctions regime rather than Georgian tax law. Source-of-funds documentation gets checked more thoroughly, which makes coming prepared with clear documentation genuinely worth the extra time.