Chapter III · Investments

Territorial taxation
liberates the investor.

Foreign stocks, ETFs, and crypto — for personal investment, the tax structure is remarkably simple. At its core: "only domestically sourced income is taxable" — the territorial logic.

The Principle

"Only domestically sourced" income
is taxable.

Under territorial taxation, foreign stocks, ETFs, and crypto are generally treated as foreign-source income and exempt from taxation. This is one of the most investor-friendly designs globally — structurally distinct from Japan\'s worldwide income taxation.

01Foreign Equity

Foreign Stocks & ETFs

Foreign-sourced, therefore tax-free in Georgia.

Dividends
0%
ON GEORGIA SIDE
Capital Gains
0%
ON GEORGIA SIDE

Apple stock, VTI, S&P 500 ETFs, and other foreign-issued equities and funds — Georgia does not tax their dividends or capital gains. Note that the source country (often the US) typically withholds tax, which is a separate consideration.

Example · Dividend

$100 dividend from Apple

US-side withholding10–30%
Georgia side0% (no additional tax)
Example · Capital Gain

Apple stock $1,000 → $1,500

Profit$500
Georgia side0% (tax-free)
02Georgian Equity

Georgian Company Equities

Domestic = taxable. Dividend 5%, capital gain 20%.

Dividend
5%
WITHHOLDING
Capital Gains
20%
FROM 2024 RULES

Georgian company shares are treated as domestic-source income and are taxable. Dividends are subject to 5% withholding; capital gains are taxed at 20%.

Dividend
5% withholding completes the obligation. Example: 100 GEL dividend from a Georgian company → 5 GEL withheld, 95 GEL received.
Capital Gains
20% on gains. Example: bought at 1,000 GEL, sold at 1,500 GEL → 500 GEL profit × 20% = 100 GEL tax.
Filing Rule (from 2024)
Filing rules changed in 2024: file and pay by the 15th of the month following sale.
03Cryptocurrency · Individuals

Crypto (Individual)

Zero tax — one of the world\'s most crypto-friendly regimes.

Capital Gains
0%
Income Tax
0%
PERSONAL USE
VAT on Exchange
0%
EXEMPT BY LAW

Crypto trading by an individual using their own funds is fully tax-exempt. Capital gains, swaps, and exchanges are all outside the tax scope. This rests on territorial taxation and the interpretation that "personal crypto trading is not business activity." This treatment remains in place as of 2026.

Sell / Swap / Stake
Sales, swaps, staking rewards, and airdrops are all tax-exempt as long as personal in nature.
Crypto ↔ Fiat
Exchanging crypto for GEL or foreign currency is VAT-exempt — treated equivalently to currency exchange.
Caveat · Business Activity
If tax authorities classify your activity as "business or self-employment," 5% income tax may apply. Determined by frequency, scale, and operational format — be cautious about the business-line threshold.
Example · Individual Trade

Bitcoin trade

Buy10,000 GEL
Sell12,000 GEL
Profit2,000 GEL
Tax payable0 GEL
04Cryptocurrency · Business

Crypto (Business)

Corporate crypto = standard corporate tax (distribution-based).

When crypto activity is conducted as a business — rather than personally — standard corporate taxation applies. Estonian-style "distribution-based" taxation still works in your favor: as long as profits are reinvested, the effective rate remains 0%.

Mining as Business
Operating mining as a business: 15% corporate tax (at distribution).
Exchange Operation
Operating a crypto exchange: standard corporate tax + VASP (Virtual Asset Service Provider) licensing and compliance required.
Corporate Holding
LLC-named crypto holdings & operations: corporate asset, taxed only at distribution (15%).
VAT Treatment
Crypto-to-crypto exchange itself is VAT-exempt. Related services (consulting, custody, etc.) are subject to 18% VAT.
Summary Matrix

Investor-friendly,
simple structure.

Investment TypeDividendCapital GainNotes
Foreign Stocks & ETFsTax-freeTax-freeSource country may withhold
Georgian Equity5%20%From 2024: file by 15th of next month
Crypto (Individual)Tax-freeTax-freeVAT-exempt
Crypto (Business)Corporate 15% (distribution only)Effectively 0% if reinvested
Residency Note

Tax exemption presumes "tax residency."

Many of these tax-exempt and preferential treatments presume that you are a Georgian tax resident. Residency is determined by either:

Rule 01 · 183 Days

Spending 183+ days in Georgia within a calendar year.

Rule 02 · Economic Center

Center of vital interests (life and economic) located in Georgia.

Japan Side
If you remain a Japanese tax resident, worldwide income taxation applies. The taxation of foreign companies and overseas investments must be aligned across both jurisdictions. Simply "opening an account abroad" does not result in tax exemption. FRONTIER CAPITAL\'s designs include Japan-side residency assessment, CFC rules, and tax treaty applications.
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