Georgia's 1% rate is real, and registering an Individual Entrepreneur here takes days. Neither fact answers the question that actually decides whether the 1% is legally yours: what does the country you are leaving require before it lets go, and what does it keep doing to you afterward? That answer is different for a German national than a Brazilian one, and it has nothing to do with Georgian law. This guide sets out the mechanics every mover needs to check, names the two structural traps that catch the most people, and compares all 29 countries we cover on the two questions that matter first - is there a tax treaty, and what is the headline trap.
What actually has to be true before the 1% is legally yours
Registering a Georgian business is the easy half. The hard half happens entirely inside your home country's tax code, and it comes down to six things.
Breaking tax residency in your home country
Every country has its own test for who counts as tax resident, and the tests differ. Day counts are the part everyone knows about; the part that actually decides close cases is the tie-breaker tests inside a double tax treaty when both countries have a claim on you in the same year - permanent home, centre of vital interests, habitual abode, and nationality, applied in that order under the standard treaty model.
Deregistration is also a filed act in most countries, not something that happens automatically the day you board a flight. Germany requires an Abmeldung. Italy requires removal from the resident population register and registration with AIRE. Spain has Modelo 030. The UK has form P85. Skip the paperwork and you can remain tax resident somewhere on paper long after you have genuinely left, which is a slower and more expensive problem to fix than to avoid.
Exit taxes: what some countries charge on the way out
A number of countries treat the act of leaving as a taxable event in itself. Unrealised gains on shares, funds or other qualifying assets are deemed sold at market value the moment you cease to be tax resident, whether or not you have actually sold anything. France, the Netherlands, Norway, Canada, Australia, Germany and several others each run a version of this, usually above an ownership percentage or value threshold. It is a bill triggered by the departure, not by a later sale, and nothing about registering a Georgian company reminds you it exists.
Trailing-residence rules: still taxable after you've left
This is the least-covered category in the English-language guidance we have read, and it is the one that decides whether the 1% is durable or just theoretically available for a year or two. Several countries keep taxing a departing national or resident as if they had never left, specifically when the destination looks like a low-tax move. Spain's art. 8.2 LIRPF and Germany's section 2 AStG are the most aggressive versions on this list - both covered in full below - and Sweden and Norway each run multi-year presumptions that put the burden of proof on you to show your ties have genuinely ended.
CFC rules: when your home country looks through the company anyway
Controlled foreign company rules let a home country tax the profits of a foreign company you control as if you had received them directly, whether or not you ever draw a dividend. Whether these rules reach a Georgian entity you own, and critically which entity, is the single most useful technical point in this whole guide, and it gets its own section below rather than a paragraph here.
The treaty position: whether there is a tie-breaker at all
A double tax treaty does two jobs that matter to a mover: it settles which country wins the residency question when both have a claim in the same year, and it caps withholding rates on cross-border payments between the two. No treaty means no tie-breaker at all - your home country's domestic law is the only rule in the room, and it has no reason to rule in your favour. Georgia currently has treaties in force with 58 countries. Four of the twenty-nine we cover here have no treaty at all, and a fifth signed one that never actually took effect. All five are named below.
Social security: the bill that does not go away
Income tax and social security run on separate tracks, and a double tax treaty does not touch the second one - only a specific totalisation agreement does, and Georgia has very few of them. The country whose citizens feel this the hardest, the United States, has none at all, which is the first of the two traps below.
The US trap: citizenship-based tax with no relief
The United States taxes its citizens on worldwide income no matter where they live, and it is one of the only countries in the world that does this. Moving to Georgia, becoming a Georgian tax resident, and never setting foot in the US again changes nothing about that fact. Registering a Georgian Individual Entrepreneur does not touch it either.
Two things compound the citizenship problem for anyone moving from the US specifically.
First, there is no US-Georgia tax treaty. None has ever been signed. That means no tie-breaker article, no reduced withholding, and no mechanism for resolving a dispute if both countries decide they can tax the same income. Every other structural conversation in this guide assumes a treaty exists to fall back on; for a US person, it does not.
Second, there is no totalisation agreement between the US and Georgia either. The US has totalisation agreements with around 30 countries that prevent double social security taxation - most of Western Europe, plus Canada, Japan, South Korea and a handful of others. Georgia is not one of them. A US citizen running self-employment income through a Georgian IE still owes US self-employment tax, currently 15.3% split across Social Security and Medicare, on top of whatever Georgia collects. The Foreign Earned Income Exclusion shelters a meaningful amount of salary-type earned income each year (its 2026 threshold sits around $132,900), but it does not shelter self-employment tax, which is calculated separately and survives the exclusion entirely.
Run the numbers plainly: a US citizen invoicing 100,000 GEL through Georgian Small Business Status pays 1,000 GEL in Georgian tax. The same person then owes US self-employment tax on the equivalent US-dollar profit, with no treaty and no totalisation agreement to offset any of it. The Georgian side of the bill is a rounding error next to the American side. This is not a reason to avoid Georgia - it is a reason to know the real total before assuming the 1% is your effective rate. Our tax consulting work with US clients starts from the US side of this equation, not the Georgian one, because that is where the number actually comes from.
The Germany trap: the ten-year tail
Germany runs the most legally dense exit position on this list, and German-language demand for Georgian company formation is high enough that getting this section right matters more than most.
Two separate provisions can each reach a departed German national, and they run independently of each other.
Section 6 AStG is Germany's exit tax on substantial shareholdings. If you have held unlimited tax liability in Germany for at least 7 of the last 12 years and own 1% or more of a corporation, moving away triggers a deemed disposal of those shares at market value on the day you leave, taxed as if you had actually sold them. It applies to real German or foreign corporate holdings you carry with you, not to a Georgian company you set up after arriving.
Section 2 AStG, extended limited tax liability, is the one that actually interacts with the Georgian 1%. German law treats a destination as a low-tax jurisdiction when its tax burden is substantially below the German equivalent - specifically, more than a third lower than what the same income would face in Germany, with an escape available only if you can show you are still paying at least two-thirds of the German amount. Where that test is met, and you keep meaningful economic ties to Germany, extended limited tax liability can keep you taxable there on certain German-source income streams for up to ten years after you leave.
A 1% turnover tax does not come close to two-thirds of anything Germany would charge on comparable income, under any realistic comparison. Georgia sits deep inside the low-tax definition German law uses, which is exactly why section 2 AStG is the provision every German mover needs answered before registering, not after.
None of this means Georgia is the wrong choice for a German national. It means the planning has to account for a ten-year tail on certain income and a real exit-tax bill on any substantial shareholding, both entirely separate from anything Georgia charges.
Does Georgia have a treaty with your country? All 29, compared
Whether a treaty exists changes the entire shape of the conversation, so it is worth seeing plainly before reading a single country guide. The table below covers the treaty position, verified against Georgia's official treaty list, and a one-line pointer to the trap that matters most for that country. Each guide linked here works through the full mechanics - residency-breaking steps, exit tax, trailing rules, CFC treatment and a worked cost comparison - from that country's own tax code.
| Country | Treaty with Georgia? | Headline trap |
|---|---|---|
| Germany | Yes | Section 2 AStG can hold you for up to 10 years; section 6 exit tax hits at 7 of the last 12 years of residence. |
| United Kingdom | Yes | The Statutory Residence Test is stricter than assumed; temporary non-residence rules tax certain income if you return within 5 years. |
| United States | No | No treaty, no totalisation agreement, and citizenship-based tax follows you regardless of residence. |
| France | Yes | Exit tax under art. 167 bis on unrealised gains, plus art. 155 A which can re-attribute income to you personally. |
| Netherlands | Yes | Box 3 taxes a deemed return on savings and investments; a 30% ruling is forfeited on departure. |
| Italy | Yes | AIRE registration is mandatory, and art. 2(2-bis) TUIR reverses the burden of proof for moves to favourable jurisdictions. |
| Spain | Yes | Art. 8.2 LIRPF can keep nationals taxable for the departure year plus four more; Modelo 720 reporting continues regardless. |
| Poland | Yes | An exit tax applies above a threshold, and Poland's CFC rules reach a foreign company at modest control levels. |
| Russia | No | Signed in 1999 and ratified by Georgia, but never ratified by Russia's Duma - it has never entered into force. |
| Ukraine | Yes | Diia City's own preferential IT regime is a genuine domestic alternative worth comparing before leaving at all. |
| Turkey | Yes | The land border makes this the easiest move on the list logistically; lira volatility matters if you keep Turkish assets. |
| Israel | Yes | The 183-day and centre-of-life tests interact awkwardly with the 10-year new-immigrant benefit if you leave mid-benefit. |
| India | Yes | NRI status and RBI/LRS remittance limits control how much money you can move out in a year, treaty or not. |
| Canada | No | No treaty, and a departure tax on deemed disposition of most property applies the day residency ends. |
| Australia | No | No treaty, and CGT event I1 deems your assets sold at market value the moment residency ends. |
| Sweden | Yes | A multi-year "essential ties" presumption keeps Swedish nationals resident by default until proven otherwise. |
| Norway | Yes | A multi-year residency tail applies alongside an exit tax on share gains above a threshold. |
| Denmark | Yes | Strict tests for what counts as genuinely leaving, plus exit taxation on unrealised gains for shares and certain other assets. |
| Belgium | Yes | The income tax gap is smaller than it looks once you account for what Belgian social contributions were funding. |
| Austria | Yes | Austria's own Wegzugsbesteuerung mirrors the German exit-tax logic for substantial shareholdings. |
| Switzerland | Yes | Cantonal variation means "Swiss tax" is not one number, and AHV social contributions are billed separately from income tax. |
| Ireland | Yes | A domicile levy can apply to wealthy Irish domiciliaries regardless of residence; split-year relief covers only part of a departure year. |
| Portugal | Yes | The NHR regime that made Portugal famous is closed to new entrants, so the real comparison is against ordinary Portuguese tax. |
| Finland | Yes | A multi-year rule presumes continued Finnish residency for nationals unless you can show your ties have genuinely ended. |
| Greece | Yes | Greece runs its own non-dom-style regime, so the real comparison is Georgia against that, not against ordinary Greek tax. |
| Czechia | Yes | The paušální daň lump-sum regime is the closest EU analogue to Georgia's 1%, making this one of the closer comparisons on the list. |
| Romania | Yes | Romania's own micro-company regime has been narrowed in recent years, which is part of why interest in Georgia has grown. |
| Kazakhstan | Yes | Astana Hub runs a genuinely competitive regional regime for qualifying tech companies, worth comparing before assuming Georgia wins. |
| Brazil | No | No treaty; exit rules apply on becoming non-resident, and interest in Georgia from Brazilian remote workers is recent and growing. |
Five of the twenty-nine have no treaty in force. The US case is covered in full above. Canada, Australia and Brazil have no treaty with Georgia either, and unlike the US, all three are at least in various stages of exploratory talks rather than a settled policy position - nothing is in force today, but nothing rules it out later. Russia is the fifth and strangest case: a treaty exists on paper, ratified by Georgia in 2000, but the Russian side never completed ratification, so it has never taken legal effect. For a national of any of these five countries, the entire "does the treaty resolve this" question above simply does not apply, and every planning decision falls back on domestic law alone.
Georgia's treaty network otherwise covers every EU country on this list, plus the UK, Turkey, Israel, India and Kazakhstan - the full set most movers ask about.
The CFC question that changes the recommended structure
Controlled foreign company rules are built to reach a foreign corporation. A Georgian Individual Entrepreneur is a sole proprietorship - legally, it is you, not a separate company you control. In a meaningful number of jurisdictions, that means CFC rules simply do not engage against a Georgian IE the way they would against a Georgian LLC, because there is no separate corporate entity for the rule to attribute income from.
This is worth sitting with, because it is the single most useful technical point in this entire cluster and almost nobody writes about it.
CFC regimes exist to stop a resident from parking profit inside a low-tax foreign company and simply not distributing it. The mechanism nearly always requires a separate legal person: a corporation, in the technical sense, that the home-country resident controls. An Individual Entrepreneur in Georgia is not that. It is a registered sole-proprietorship form - the income is legally yours from the moment it is earned, the same way a freelancer's invoice is legally theirs. There is no corporate shell for a CFC rule to look through, because there is nothing separate from you to look through in the first place.
A Georgian LLC is a different animal entirely. It is a separate legal person with its own bank account and its own balance sheet, and it is squarely the kind of entity CFC rules are written to catch. Retained profit sitting inside a Georgian LLC you control can be attributed straight back to you under your home country's CFC rules, taxed as if distributed, years before you ever take a dividend.
The practical consequence is that the same person can face two entirely different CFC outcomes depending on which structure they register, and this is exactly why our free tax consultation always starts with the structure question before anything else. None of this generalises safely. Some countries' CFC rules are drafted broadly enough to reach any controlled foreign arrangement, transparent entity or not; others follow the corporate-entity logic closely enough that an IE genuinely sits outside scope. It is a per-country question, checked against that country's actual CFC statute, not an assumption to carry from one guide to the next - which is exactly why every country guide in this cluster answers it separately rather than pointing back here.
Using the country guides properly
Each of the 29 guides linked in the table above follows the same shape: what you would pay at home against what you would pay here, whether the 1% genuinely applies to your situation, the actual steps to break residency in that specific country, what that country charges or continues to claim on the way out, the CFC answer for an IE and for an LLC separately, the treaty position, the social security position, what ongoing reporting survives your departure, a realistic timeline, and a plain verdict. Some countries get a strong-fit verdict. A few get "usually not worth it," and we publish that too, because a guide that only ever says yes is not worth reading.
If your country is not written yet, the short version above and the table's headline trap will get you most of the way to knowing what to check. If your situation is close to the line on any of the six factors, particularly CFC exposure or a trailing-residence rule, that is exactly the kind of question worth a proper answer before you register anything. Georgian Small Business Status and Georgian tax residency are the two pieces on the Georgian side of the equation worth reading alongside whichever country guide applies to you, and our own double tax treaty guide covers how to actually invoke a treaty once one exists.
Bring your situation - where you are leaving from, what you hold, how you earn - and we will tell you plainly whether the 1% survives contact with your home country's rules, and what still needs resolving on that side before you register anything here.
Book the free call
For anyone not planning to relocate physically before registering, registering remotely is available under power of attorney, and it does not change any of the analysis above - the questions in this guide are about your home country's law, not about where you happened to sign the paperwork. Once the structure is settled and running, monthly accounting and the compliance calendar are the same regardless of which of the 29 countries you came from, and our Common Reporting Standard guide covers what actually gets reported back to your home tax authority once the account is open.
Key takeaways
- Six things decide whether the 1% is legally yours: residency-breaking, exit taxes, trailing rules, CFC exposure, treaty position and social security.
- The US has no treaty and no totalisation agreement with Georgia; citizenship-based tax follows you regardless of residence.
- Germany's section 2 AStG can tax a departing national for up to 10 years when the destination taxes well below Germany's rate - Georgia's 1% qualifies.
- Canada, Australia and Brazil have no Georgian treaty. Russia's 1999 treaty was never ratified in Moscow, so it never took effect.
- Georgia has treaties in force with 58 countries, including every EU country here, the UK, Turkey, Israel, India and Kazakhstan.
- CFC rules generally reach a foreign corporation, not a sole proprietorship - a Georgian IE and an LLC can produce different outcomes under the same statute.
- None of this generalises - every guide answers these six questions from that country's own tax code.
Frequently asked questions
Does moving to Georgia automatically make me eligible for the 1% tax?
No. Registering an Individual Entrepreneur and getting Small Business Status is a Georgian process that takes days. Whether the arrangement is durable depends entirely on what your home country's tax code still claims about you, which is a separate question this guide and the linked country guides work through.
Which countries have no tax treaty with Georgia?
The United States, Canada, Australia and Brazil have no tax treaty in force with Georgia. Russia is a related but different case: a treaty was signed in 1999 and ratified by Georgia, but the Russian Duma never ratified it, so it never entered into force.
How many countries does Georgia have a tax treaty with?
58, according to Georgia's Ministry of Finance. That covers every EU country in our list of 29, plus the UK, Turkey, Israel, India and Kazakhstan.
Why is the US treated as a special case in this guide?
Because two things compound at once for a US citizen: there is no US-Georgia tax treaty, so there is no tie-breaker if both countries claim taxing rights, and there is no totalisation agreement, so US self-employment tax keeps applying on top of Georgia's 1%. Citizenship-based taxation also means a US citizen owes US tax on worldwide income regardless of where they live.
Does the Foreign Earned Income Exclusion solve the US problem?
Only part of it. The exclusion shelters a meaningful amount of salary-type earned income each year, but it does not shelter self-employment tax, which is calculated separately and applies in full regardless of the exclusion.
What is Germany's section 2 AStG and does it really apply to Georgia?
It is Germany's extended limited tax liability rule, which can keep a departing German national taxable on certain income for up to ten years when the destination taxes substantially below the German equivalent and meaningful economic ties to Germany remain. Georgia's 1% sits well inside the threshold German law uses to define a low-tax destination, so the rule is a real planning question for German movers, not a theoretical one.
What is an exit tax and does Georgia have one?
An exit tax treats emigration as a taxable event, deeming certain assets sold at market value the moment you stop being tax resident, whether or not you actually sold anything. It is a feature of the country you are leaving, not Georgia - France, the Netherlands, Norway, Canada, Australia and Germany all run versions of it, each with its own thresholds.
Do CFC rules apply to a Georgian company I control?
It depends on the entity and the country. CFC rules are generally built to reach a foreign corporation, and a Georgian Individual Entrepreneur is a sole proprietorship rather than a separate legal entity, so in a meaningful number of jurisdictions the rules do not engage at all against an IE the way they would against a Georgian LLC. This varies by country and needs checking against that country's specific CFC statute rather than assumed.
Will my home country find out that I registered a business in Georgia?
Treat it as visible rather than hidden. International tax information exchange between countries is routine, and assuming otherwise is not a safe basis for a decision you plan to rely on for years.
Is there a country where the answer is genuinely "don't bother"?
Yes, and the individual guides say so plainly where it applies. A country with a strong domestic alternative already close to Georgia's rate, or trailing-residence rules aggressive enough to erase the saving for years, can make the honest verdict "usually not worth it" rather than a forced yes.
My country isn't on the list of 29 - does any of this still apply?
The six factors in this guide - residency-breaking, exit tax, trailing rules, CFC exposure, treaty position and social security - apply to moving from anywhere, even where we have not written a dedicated guide yet. The mechanics above are the right starting checklist regardless of which country you are leaving.