Moving from Spain to Georgia for the tax rate is the easy part to research. Registering an Individual Entrepreneur and getting Small Business Status takes days, and the 1% is real. What decides whether it actually holds up for a Spanish national is a single, specific question most guides skip or get wrong: is Georgia on Spain's list of non-cooperative jurisdictions under article 8.2 LIRPF? That provision keeps Spanish nationals taxable at home for the year of departure plus four more if the answer is yes. We checked it directly against the current official list, and the answer is no - the fact this entire guide is built around.
What EUR 80,000 of freelance income actually costs, here and there
Start with the number, because it is the reason anyone reads this far.
Take a Spanish autónomo in Madrid turning over EUR 80,000 a year, with modest costs bringing net profit to around EUR 75,000. Spain's 2026 RETA contribution runs on 15 brackets tied to real net monthly income, and a net profit of roughly EUR 6,250 a month sits in the top bracket, at approximately EUR 607 a month including the Mecanismo de Equidad Intergeneracional, confirmed on the 2026 RETA bracket table - about EUR 7,288 a year. RETA is deductible before IRPF, bringing the taxable base to roughly EUR 67,712. Applying Madrid's combined state-plus-regional IRPF scale for 2026 - 19% to EUR 12,450, rising to 45% above EUR 60,000, published on Madrid's 2026 IRPF bracket table - produces income tax of roughly EUR 21,372.
| Spain (autónomo, Madrid, 2026) | Georgia (IE + Small Business Status) | |
|---|---|---|
| Turnover / net profit | EUR 75,000 net profit | EUR 80,000 turnover |
| RETA social security | ~EUR 7,288 | None required by the status itself |
| IRPF (Madrid combined scale) | ~EUR 21,372 | 1% of turnover |
| Total, all-in | ~EUR 28,660 (~36%) | ~EUR 800 (~1%) |
This is Madrid-specific and illustrative - other autonomous communities set their own regional scale - but it shows honestly where the Spanish bill actually sits.
Does Georgia's 1% actually apply to you
The 1% only applies to Georgian-source income, and for services that generally means work physically performed inside Georgia, not work billed through a Georgian registration while you sit in Madrid or Barcelona. We cover this fully in Georgia's 1% tax and 1% tax without living in Georgia. A Spanish national who registers a Georgian IE and keeps working from home has a source-of-income problem before the residency questions below even matter, because the work never actually left Spain.
What Spain does when you leave
Article 9 LIRPF sets Spanish tax residency on three independent grounds, and any one is enough to keep you resident. The first is the familiar 183-day count within the calendar year, counting sporadic absences unless you can prove tax residency elsewhere. The second is having your centro de intereses económicos - the core of your economic activities and interests - located in Spain; spending fewer than 183 days there does not help if the bulk of your income, assets and business activity are still generated or managed from Spain. The third is a rebuttable presumption: if your spouse, not legally separated, and dependent minor children habitually reside in Spain, you are presumed Spanish tax resident too, unless proven otherwise. A Spaniard who moves alone while a spouse and children stay in the family home starts from a position the Agencia Tributaria will treat as resident by default.
Someone who moves abroad without keeping an economic activity registered in Spain files Modelo 030 to notify the change of fiscal domicile, generally within three months. It is a required administrative notification, not a substitute for satisfying article 9 LIRPF - it tells the Agencia Tributaria your address changed, and says nothing about your centro de intereses económicos or where your spouse and children are living.
This is the fact the entire guide turns on. Article 8.2 LIRPF provides that a Spanish national who moves their tax residence to a jurisdiction classified as a non-cooperative jurisdiction does not lose Spanish taxpayer status - they remain taxable in Spain for the year of the change plus the following four tax periods, a citizenship-based rule that applies specifically because of the destination. We checked Spain's current list under Orden HFP/115/2023 directly against the Agencia Tributaria's own published Anexo of non-cooperative jurisdictions, a couple of dozen jurisdictions including Anguilla, Bahrain, Bermuda, Fiji, Guernsey, the Cayman Islands, Jersey, Vanuatu and Russia. Georgia does not appear on it, under any name. Article 8.2's five-year extended taxpayer status therefore does not apply to a Spanish national moving here - the single most important fact in this guide, and the one that flips the verdict from "do not bother" to "works." Article 8.2 only applies to Spanish nationals; a non-Spanish citizen who is Spanish tax resident and moves to Georgia is governed entirely by article 9 above.
Spain's transparencia fiscal internacional, article 91 LIRPF, imputes certain income earned by a non-resident entity to a Spanish resident who controls it, whether or not distributed, confirmed on the Agencia Tributaria's scope-of-application page, once two conditions are met: 50% or more control, and an effective foreign tax below 75% of the Spanish equivalent. But the statute's list of imputable income, set out in article 91 LIRPF, is a closed list of passive categories - real estate income, dividends, interest, royalties, insurance and similar. A Georgian IE has no separate legal personality, so there is no "entidad" to attribute income from - it is already the individual's own the moment earned. A Georgian LLC is a separate entity and can be caught if you control 50% or more of it, but only for those listed passive categories; one earning ordinary active service income to unrelated clients generally falls outside the net regardless of Georgia's low effective rate.
Spain and Georgia have a working double taxation convention, signed in Madrid on 7 June 2010 and in force from 1 July 2011, published in the Boletín Oficial del Estado as BOE-A-2011-9527. It does nothing to switch off article 8.2, though that provision is not engaged for a move to Georgia in the first place.
Anyone who previously filed Modelo 720, the annual declaration of assets abroad above EUR 50,000, needs to check whether that obligation continues based on where they remain resident - it is tied to residency, not nationality, so it generally stops once residency is genuinely broken, but Spanish-source income kept after leaving remains taxable in Spain as a non-resident regardless of the move.
The steps, in order
- Confirm article 9 LIRPF is genuinely closed on all three tests - day count, centro de intereses económicos, and where your spouse and minor children actually live.
- File Modelo 030 to notify the change of fiscal domicile, generally within three months of the move, treating it as paperwork rather than proof residency has ended.
- Resolve where your spouse and children will actually live before assuming your own residency is broken - the family presumption is rebuttable, not automatic.
- 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 if article 91 LIRPF exposure is a live concern, since an IE sits outside it structurally while an LLC only escapes if its income is genuinely active.
- Check whether Modelo 720 reporting continues based on your new residency status and what you still hold.
- Confirm your Georgian tax residency position separately from the registration itself, since holding Small Business Status does not by itself make you tax resident here.
Timeline and cost
The Georgian side is fast: an Individual Entrepreneur with Small Business Status is typically registered within days in person, or a few weeks under power of attorney. The Spanish side takes longer to close out properly - filing Modelo 030, confirming the article 9 LIRPF position against your actual ties including where your family lives, and checking whether Modelo 720 reporting continues. Budget for a gestor or asesor fiscal to close out the departure year correctly, particularly if a spouse or minor children are not relocating on the same timeline.
The verdict for a Spanish national
Georgia is a strong fit for a Spanish national who genuinely relocates. The blacklist question, the single fact that could have flipped this entire guide to "usually not worth it," comes out clean: Georgia is not on Spain's list of non-cooperative jurisdictions, so article 8.2 LIRPF's five-year trailing liability never engages. A real treaty has been in force since 2011, and even transparencia fiscal internacional - which, like Italy's CFC rules, can reach individuals directly - leaves a Georgian IE outside its scope entirely and an LLC out of scope too, provided its income is genuinely active. What remains are the ordinary conditions: genuinely satisfy article 9 LIRPF rather than relying on Modelo 030 alone, resolve where your spouse and children will actually live, and pick an IE or an LLC based on how the underlying income is earned.
We'll work through whether your Spanish residency is genuinely breakable given your specific ties, what article 91 LIRPF means for an IE versus an LLC in your case, and confirm the blacklist position stays clean for your exact situation before you register anything here.
See what it costs
For the same analysis built for a different departure point, see our guides on moving from the Netherlands to Georgia and moving from Italy to Georgia, and for how Georgian-source income is actually defined, see Georgian-source income rules. A free consultation is the fastest way to get a straight answer on where your own situation actually sits.
Key takeaways
- Confirm all three article 9 LIRPF tests are closed - day count, centro de intereses económicos, and where your spouse and minor children live.
- File Modelo 030 within three months of the move, but treat it as notification, not proof residency has ended.
- If a spouse or minor children stay in Spain, resolve that before assuming your own residency is broken.
- Pick an IE if article 91 LIRPF exposure is a concern; an LLC only clears it if its income is genuinely active rather than passive.
- Check whether Modelo 720 reporting continues once you are genuinely non-resident.
- Register the Georgian IE and Small Business Status only once the Spanish side above is genuinely resolved.
Frequently asked questions
Is Georgia on Spain's blacklist?
No. We checked Spain's current list of non-cooperative jurisdictions under Orden HFP/115/2023 directly against the Agencia Tributaria's own published list, and Georgia does not appear on it. This means article 8.2 LIRPF's five-year extended taxpayer status for Spanish nationals does not apply to a move here.
What is article 8.2 LIRPF and who does it affect?
It is a rule that keeps Spanish nationals - not foreign nationals resident in Spain - taxable as Spanish taxpayers for the year they change residence plus the following four years, but only if they move to a jurisdiction on Spain's list of non-cooperative jurisdictions. Since Georgia is not on that list, this provision does not engage for a genuine move there.
Is Modelo 030 enough to end my Spanish tax residency?
No. Modelo 030 notifies the Agencia Tributaria of a change of fiscal domicile, but Spanish tax residency under article 9 LIRPF is a separate, substantive test based on day count, centre of economic interests, and family location. Filing the form does not by itself satisfy any of those tests.
What is centro de intereses económicos and why does it matter?
It is one of three independent tests for Spanish tax residency under article 9 LIRPF: if the core of your economic activities and interests remains located in Spain, you can be considered resident even if you spend fewer than 183 days there in a given year.
Does having my spouse and children stay in Spain affect my own tax residency?
Yes, potentially significantly. Article 9 LIRPF creates a rebuttable presumption that you remain Spanish tax resident if your spouse, not legally separated, and dependent minor children habitually reside in Spain, even if you personally have relocated.
Do Spanish CFC rules reach a Georgian Individual Entrepreneur?
No. Article 91 LIRPF's transparencia fiscal internacional regime requires a separate non-resident "entidad." A Georgian IE has no separate legal personality, so there is no foreign entity for the rule to attribute income from.
Does the same apply to a Georgian LLC?
Not automatically. A Georgian LLC is a separate legal entity and can be caught if you control 50% or more of it and its effective tax rate is below 75% of the Spanish equivalent. But the regime only imputes specific passive income categories, so an LLC earning genuine active service income generally falls outside it.
Do I still need to file Modelo 720 after I leave Spain?
Generally not, once you are genuinely no longer Spanish tax resident, since the obligation is tied to residency rather than nationality. Anyone who already filed it should confirm their new status and whether any Spanish-situated assets still trigger a filing requirement as a non-resident.
Can I keep Spanish clients after I move to Georgia?
Yes, but income that remains Spanish-source may still be taxable in Spain as a non-resident regardless of where you live, and if your spouse or minor children remain in Spain, the family-residence presumption under article 9 LIRPF can keep your own residency in question too.