Granting of Active Taxpayer Status

On 11 June 2026, Order No. 180 of the Minister of Finance of Georgia was published, introducing amendments to the Instruction on Tax Administration.

The amendments entered into force on 12 June 2026 and expanded the grounds for granting active taxpayer status.

Active status may be granted to a taxpayer if:

  • a POS terminal, a mobile POS terminal or an e-commerce terminal is registered in the taxpayer’s name, and its registration has not been cancelled as of the date on which the relevant status is granted;
  • the enterprise or organisation holds a bank account that is active at the moment the status is granted;
  • the taxpayer has issued a tax document (TD);
  • the taxpayer holds micro business, small business or fixed taxpayer status that is valid as of the relevant date;
  • the person is registered as a VAT payer and that registration has not been cancelled as of the date on which the status is granted.

These amendments do not abolish the grounds for granting active status that already existed; rather, they add further criteria to them. Accordingly, the other grounds currently in force remain valid, including registration of the taxpayer, filing of the declarations and computations required by legislation, fulfilment of tax obligations, recording of turnover through a cash register, and other cases determined by legislation.

Simplified Rules for Maintaining the Book of Income and Expenses

On 24 June 2026, Order No. 196 of the Minister of Finance of Georgia was published, introducing amendments to the Instruction on Tax Administration. The amendments will enter into force on 1 August 2026 and concern the rules for maintaining the simplified book of income and expenses.

Under the new rules, a person entitled to apply the simplified method of accounting for income and expenses may maintain the accounting book either on paper or in electronic form. All business transactions of the reporting (tax) period must be recorded in the accounting book in chronological order, on the basis of primary accounting documents.

The procedures for administering the accounting book have also been simplified. In particular, the provisions of Article 28 of Order No. 996 that provided for the sealing of the accounting book by the Revenue Service have been removed. Consequently, taxpayers will no longer have to apply to the tax authority for that purpose.

Under the updated rules, the accounting book is, as a rule, opened for one calendar year. However, where the specific nature of the activity so requires (for example, where a person operates several stationary facilities or carries out activities in different regions), more than one accounting book may be maintained.

It has additionally been established that:

  • an accounting book maintained on paper must be bound (laced) and its pages numbered, whereas this requirement does not apply to the electronic form;
  • corrections of errors made in the accounting book must be duly substantiated and must indicate the date of the correction; in the case of a paper book, the correction must also be confirmed by the taxpayer’s signature and, where one exists, by a seal;
  • if a person no longer has the right or the obligation to apply the simplified accounting method, that person must cease maintaining the relevant accounting book;
  • the minimum retention period for the accounting book has been set at no less than 3 years.

As a reminder, under Article 73 of the Tax Code of Georgia, the simplified method of accounting for income and expenses may be applied by persons who sell goods or services predominantly for cash. This method does not extend to taxpayers who, for corporate income tax and personal income tax purposes, are required to keep, or voluntarily keep, accounting records on an accrual basis, or to payers of value added tax (VAT).

The amendments are aimed at simplifying the accounting process, promoting record-keeping in electronic form and reducing the administrative burden on taxpayers.

Increase in the Fee for Issuing an Advance Tax Ruling

Resolution No. 251 of the Government of Georgia, published on 8 June 2026, increased the service fee charged by the Revenue Service for issuing an advance tax ruling.

Under the change, from 1 January 2027 the service fee will amount to GEL 20,000 for legal entities and GEL 10,000 for resident natural persons. The previously applicable rates were GEL 10,000 and GEL 5,000 respectively.

The new rates will apply only to requests submitted to the Revenue Service on or after 1 January 2027. Applications submitted before that date will remain subject to the old rates.

Clarified Approach to the Taxation of Income from the Sale of Assets

On 10 June 2026, Public Decision No. 175 of the Minister of Finance of Georgia was published, amending Public Decision No. 143 of 14 May 2026 on issues of personal income taxation of income received by a natural person as a result of the supply of assets.

Under the new wording, an activity is regarded as systematic and organised only where the person creates, acquires or disposes of assets as their principal and independent economic activity, the purpose of which is to generate ongoing income.

Accordingly, the mere ownership of immovable property, including the ownership of several residential apartments or houses, the length of the holding period or a subsequent sale does not, in itself, constitute sufficient grounds for treating the activity as entrepreneurial.

At the same time, the sale by a private individual of their own assets must be distinguished from cases in which the creation, acquisition or sale of immovable property is carried out within the framework of a business activity, for example where development activities are involved, where transactions relate to the enforcement of mortgage-secured claims, or in other similar economic activities.

In such cases, a natural person may not benefit from the preferential taxation regimes provided for by the Tax Code, including:

  • the rule set out in Article 81(3) of the Tax Code of Georgia, under which surplus (gain) income is taxed at a rate of 5%, will not apply;
  • the exemption provided for by Article 82(1)(v.a) of the Tax Code of Georgia, under which the surplus income received from the sale of a residential apartment (house) owned for more than 2 years, together with the land attached to it, is exempt from personal income tax, will not apply.

The amendment therefore draws an even clearer line between the one-off sale of a private asset and the supply of assets carried out within the framework of a business activity, which is important for correctly determining the applicable tax regime.

The change entered into force on 11 June 2026.