Georgia is strengthening its regulatory framework on Transfer Pricing with new reporting requirements set to take effect in 2026. These measures aim to increase transparency in cross-border transactions and provide the tax authority with more structured information to identify potential transfer pricing risks.
The reform reflects a broader international trend in which tax authorities are seeking greater visibility into the activities of multinational groups and intra-group transactions.
New Reporting Requirements
The new obligation stems from amendments introduced on February 24, 2026, to Order No. 996 of the Georgian Minister of Finance. Under these changes, Georgian companies and Georgian permanent establishments engaging in international controlled transactions must submit additional information to the Georgian Tax Service as part of their corporate income tax return.
Companies operating under Georgia’s “Estonian model” corporate income tax regime must file a specific annex titled “Information on International Controlled Transactions” along with their corporate income tax return filed in March.
This requirement applies when the total value of international controlled transactions exceeds 500,000 Georgian lari (GEL) during the relevant tax year. The threshold includes not only direct transactions but also outstanding balances related to controlled transactions, such as accounts receivable and payable. Transactions conducted without consideration or through barter agreements must also be taken into account when determining whether the threshold has been exceeded.
The deadline for filing transfer pricing information with the Georgian Tax Service is April 15, 2026.
Scope of Controlled Transactions
Under Georgia’s transfer pricing framework, international controlled transactions include cross-border transactions between related parties or transactions involving entities located in preferential tax jurisdictions.
These transactions may involve the purchase or sale of goods, the provision or receipt of services, financial transactions such as intra-group loans, royalty payments, or other commercial agreements between related parties. If the combined value of such transactions exceeded 500,000 GEL during the 2025 tax year, the Georgian company or permanent establishment must disclose detailed information in its March 2026 corporate income tax return.
Companies must also indicate whether transfer pricing documentation has been prepared. This requirement allows the tax authority to assess whether the company has conducted an analysis supporting the arm’s length nature of its transactions.
Implications for Companies
The introduction of this reporting obligation is expected to improve the Georgian tax authority’s ability to identify companies engaged in significant cross-border transactions and may lead to increased scrutiny of transfer pricing. By having access to more structured information, the tax administration will be able to identify potential risks more efficiently and prioritize cases for a more detailed review.
For companies, this change highlights the importance of reviewing transfer pricing policies and ensuring that adequate documentation is in place. Preparing transfer pricing documentation in advance can significantly reduce potential tax risks during audits and support compliance with the arm’s length principle.
Conclusion
The introduction of the transfer pricing reporting requirement in Georgia represents an important step toward strengthening tax transparency and oversight of international controlled transactions. As regulatory scrutiny continues to increase, companies operating in Georgia should proactively review their transfer pricing policies and ensure they have adequate documentation.
TPC Group supports multinational organizations in analyzing their cross-border transactions, preparing transfer pricing documentation, and adapting to constantly evolving international tax compliance requirements.
Source: Forbes Georgia