Choose the operating model before the tax label
Georgia offers several targeted regimes, but they are not interchangeable. A FIZ enterprise is a zone-based company with customs and domestic-trade constraints. Virtual Zone and International Company statuses target defined activities and conditions. Small-business status is for qualifying entrepreneur natural persons, not a generic low-tax company regime.
Regime-screening matrix
| Regime | Potential fit | Critical exclusions or tests |
|---|---|---|
| Free Industrial Zone enterprise | Export-oriented production, processing, assembly or logistics physically linked to a recognised zone. | Domestic Georgian goods flows trigger a 4% rule; services with Georgian persons are restricted; zone licence and customs operations matter. |
| Virtual Zone person | Qualifying information-technology activity under the statutory status. | Activity, source, delivery evidence and non-qualifying services must be separated and documented. |
| International Company | Defined qualifying activities carried out by an eligible Georgian enterprise with required substance and status. | Ownership/history, permitted activities, employee/substance and ongoing conditions require specialist review. |
| Small business | Qualifying entrepreneur natural person with eligible activity and turnover conditions. | Not a corporate LLC status; excluded activities, threshold and recordkeeping apply. |
| Special trading / other statuses | Specific trading, tourism, pharmaceutical, high-mountain or other statutory models. | Each has its own eligible person, licence/status, transaction and reporting rules. |
Five questions before applying
- Who can legally hold the status: company, FIZ enterprise or entrepreneur natural person?
- Which revenue streams qualify, and which must be excluded or separated?
- Where are employees, equipment, decision-makers and delivery actually located?
- Who are the customers and suppliers—foreign, Georgian, related or inside the same zone?
- Which certificate, application, reporting, payroll, customs and renewal obligations continue after approval?
FIZ is a supply-chain regime
A Free Industrial Zone structure can be compelling for export production, but it is not a general offshore company. The Tax Code applies a 4% payment to defined supplies of goods between a FIZ enterprise and Georgian-registered persons, restricts services supplied to Georgian persons and limits services purchased from them to listed categories and any government-approved additions.
Use the dedicated Free Industrial Zones in Georgia guide to compare locations, tax mechanics, customs flow and due diligence.
Evidence and substance file
- Status decision, licence and current zone/operator agreement where applicable.
- Employee list, job descriptions, workplace and equipment supporting the qualifying activity.
- Customer and supplier classification with jurisdiction and related-party status.
- Contracts, statements of work, delivery evidence and IP ownership.
- Revenue ledger separating qualifying, non-qualifying and domestic transactions.
- Tax opinions and change log for new services, countries, staff or business lines.
Annual risk review
Eligibility can change when a company adds local customers, outsources work, moves staff, changes ownership, begins resale activity or stops maintaining required substance. Review the status before—not after—new transactions start.
Frequently asked questions
Frequently asked questions
Can an ordinary LLC call itself a Free Industrial Zone enterprise?
No. A FIZ enterprise is established under the Free Industrial Zones law and registered within a recognised zone under the applicable rules.
Is small-business status available to every LLC?
No. The small-business regime is associated with a qualifying entrepreneur natural person and its statutory conditions, not a general corporate LLC election.
Can one company mix qualifying and non-qualifying revenue?
Sometimes rules permit separation; in other cases the mix can jeopardise the status or require ordinary taxation. The exact status and revenue streams must be reviewed before contracting.