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 parties in Georgia are defined when control or ownership surpasses 50%, with a focus on management and capital.
Georgia offers a unilateral advance pricing agreement (APA) covering three years. It does not allow rollback, and the application fee is GEL 30,000.
Revenue Service of Georgia conducts audits. New regulations consider non-compliant related party transactions as profit distribution.
Transfer pricing documentation includes comprehensive data, from business operations and structure to comparability analysis.
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.