Transfer Pricing
Country Summary

This document provides insights into Georgia’s transfer pricing regulations. Despite not being part of the OECD, Georgia’s transfer pricing rules align with international standards. Key highlights include related party definitions based on control and ownership, unilateral advance pricing agreements, comprehensive transfer pricing documentation requirements, industry and functional analysis, and specific penalties for non-compliance.


Alignment with International Standards

Georgia’s transfer pricing landscape, though not an OECD member, aligns with international standards. It introduced documentation requirements in 2020, embracing practices such as country-by-country reporting (CbCR) for multinational entities.

Related Party Definition

Related parties in Georgia are defined when control or ownership surpasses 50%, with a focus on management and capital.

Advance Pricing Agreements

Georgia offers a unilateral advance pricing agreement (APA) covering three years. It does not allow rollback, and the application fee is GEL 30,000.

Audit Practices

Revenue Service of Georgia conducts audits. New regulations consider non-compliant related party transactions as profit distribution.

Detailed Documentation

Transfer pricing documentation includes comprehensive data, from business operations and structure to comparability analysis.

Method Selection

Georgia follows OECD guidelines for transfer pricing methods, without a strict hierarchy.


Penalties are imposed for non-compliance with transfer pricing documentation, with specific amounts for different violations.

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