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New Transfer Pricing Reporting Requirements in Georgia From 2026
From 2026, transfer pricing in Georgia has become increasingly important. Georgian companies and Georgian permanent establishments (PEs) conducting international controlled transactions must submit additional transfer pricing information to the Georgia Revenue Service (GRS).
The new reporting requirement applies when the total value of international controlled transactions (including the remaining balances of receivables and payables arising from controlled transactions) exceeds GEL 500,000 in 2025.
The new Georgian transfer pricing reporting obligation arises from amendments dated February 24, 2026, introduced to Order No. 996 of the Minister of Finance of Georgia.
Specifically, such Georgian companies or Georgian PEs subject to the “Estonian Model” of Corporate Income Tax (CIT) in Georgia must submit, together with the March CIT return the form titled:
“Information on International Controlled Transactions Provided for by Articles 126–129¹ of the Tax Code of Georgia.”
The GEL 500,000 threshold also includes:
- free-of-charge international controlled transactions, and
- barter controlled transactions.
In other words:
If in 2025 your Georgian company or a Georgian Permanent Establishment conducted international controlled transactions exceeding GEL 500,000 (including outstanding receivable and payable balances arising from such transactions), you are required to complete the new annex to the March Corporate Income Tax return and disclose detailed information about these controlled transactions. Such information includes, for example, the amount of controlled transactions, identification of the counterparties, starting date of the controlled operation, and other relevant details. The report must also indicate whether Georgian transfer pricing documentation (Local File) has been prepared by the company or PE.
The Revenue Service has also announced this legislative update:
https://rs.ge/LawNewsArchive?newsId=1711
Key Facts About Georgia’s New Transfer Pricing Reporting Rules (2026)
- TP Reporting applies if controlled transactions exceed GEL 500,000
- Applies to Georgian companies and Georgian PEs of foreign entities
- Report must be submitted together with March Corporate Income Tax return
- The deadline for submitting the Transfer Pricing related information to GRS is 15th of April 2026
- In the report companies/PEs must indicate whether transfer pricing documentation exists
Transfer pricing rules in Georgia are largely based on the OECD Transfer Pricing Guidelines, which require related-party transactions to comply with the arm’s length principle. To learn more about transfer pricing rule and Transfer pricing documentation in Georgia, please refer to another article by the author.
What Are International Controlled Transactions Under Transfer Pricing Rules In Georgian?
If a Georgian company or a Georgian Permanent Establishment conducts one of the following business operations with an associated foreign entity (including a foreign head office) or with any person resident in an offshore (tax haven) jurisdiction:
- purchase or sale of goods
- receipt or provision of services (including financial services, such as loans)
- receipt or payment of royalties
- any other type of business transaction (including transfer of business activity)
Such business operations are considered international controlled transactions under transfer pricing rules in Georgian. If the total value of such transactions exceeded GEL 500,000 in 2025 (including outstanding receivable and payable balances with these parties), the Georgian company or PE must submit a detailed report to the Georgia Revenue Service together with the March 2026 CIT return.
What the New Transfer Pricing Reporting Rules Mean for Companies/PEs in Georgia?
The main conclusion from the recent change in the Georgian Transfer Pricing reporting rule is that Georgian tax authority is strengthening its control over companies which are potential subject of Transfer Pricing inspection.
Through this reporting requirement, the Georgia Revenue Service will be able to more easily identify companies conducting international controlled transactions, which are potential candidates for transfer pricing audits by GRS.
Until now, the tax authority of Georgia has not had systematically organized information about Georgian companies which may be subject Transfer Pricing tax inspection in Georgia.
How the New Reporting Rules May Increase Transfer Pricing Audits in Georgia
In the author’s view, the main consequence of the new transfer pricing reporting obligation will likely be a significant increase in transfer pricing inspections by the Georgia Revenue Service.
This is because the tax authority will now have direct information about companies engaged in international controlled transactions, making it easier to identify companies that may be subject to potential tax inspections or increased monitoring related to transfer pricing in Georgia.
One of the most important aspects of the new transfer pricing-related annex to the Georgian Corporate Income Tax return appears to be that companies must also declare whether transfer pricing documentation has been prepared, and if not, whether they plan to prepare it in the future.
In the author’s view (this is a personal opinion), starting from April 2026, companies that indicate in the annex that transfer pricing documentation has not been prepared may face increased scrutiny from the tax authorities of Georgia.
On the other hand, the Georgian tax authority may also request and review transfer pricing local files from companies that declare that transfer pricing documentation has already been prepared.
What Georgian Companies/PEs Conducting Controlled Transactions Should Do Now
Georgian companies and permanent establishments conducting cross-border transactions with related foreign companies or with offshore resident persons should review their transfer pricing policies and ensure that appropriate documentation is prepared. In practice, preparing transfer pricing documentation in advance significantly reduces tax risk during potential inspections by the Georgia Revenue Service.
Such companies/PEs should be prepared for potential transfer pricing inspections or monitoring by the Georgia Revenue Service. They must ensure that their transfer pricing policy is in line with market (arm’s length) principles, that all potential transfer pricing risks are properly identified and addressed, and that high-quality transfer pricing documentation is prepared either annually or every three years (depending on the turnover of the Georgian company or PE).
Completing the Transfer Pricing appendix to the March Corporate Income Tax return should not be the most and the only important task for companies. Instead, they should carefully analyze their transfer pricing situation and prepare an objective and well-documented transfer pricing report, during the preparation of which potential transfer pricing risks are identified and addressed as much as possible. This approach will help ensure that companies are better prepared for potential tax inspections related to transfer pricing in Georgia.
Note: This article is provided for informational purposes only and does not constitute legal or tax advice.
About the author: Gela Barshovi is a Georgian tax consultant and transfer pricing specialist and the founder of TPSolution, a Tbilisi-based tax advisory firm specializing in transfer pricing, international taxation, and Georgian tax law. He regularly advises multinational companies operating in Georgia on transfer pricing documentation, tax risk assessment, and international tax structuring.
