In April 2026, our Managing Partner and international and Georgian tax consultant, Gela Barshovi, was invited by the Ministry of Finance of Georgia (MOF) and the Georgia Revenue Service (GRS) to participate in a 3-day working meeting focused on draft Public Rulings of Ministry of Finance of Georgia under Georgian tax law.
The meetings were held on April 24–26 in Tsinandali, Kakheti region of Georgia and brought together a small group of selected consulting and accounting firms (majority of which were international (such as big 4) accounting firms).
Notably, our firm is among a handful of tax consultants in Georgia regularly invited, due to their experience, to provide input on such draft decisions — contributing to the tax policy development process.
What Are Ministry of Finance Public Rulings in Georgia?
Public Decision/Rulings issued by the Ministry of Finance are official interpretations of tax law in Georgia. They are designed to clarify how tax legislation should be applied in practice, especially in areas where wording may be open to interpretation.
For businesses and individuals seeking tax consultation in Georgia, these public rulings are highly relevant because they:
- Clarify how the Georgian tax authorities interpret complex tax law provisions;
- Reduce uncertainty in the practical application of Georgian tax law;
- Lower the risk of future tax disputes with the Georgian Revenue Service.
In practice, Public Rulings often have a direct impact on corporate taxation, tax exemptions for individuals in Georgia, the definition of foreign-source income for personal income tax exemption purposes, tax structuring, VAT taxation, and other important tax issues in Georgia.
It shall be noted that, although the main purpose of a public tax ruling is to clarify interpretative legal norms, in practice, certain ambiguities regarding the specific case for which the public ruling was issued may still remain, even after the ruling is issued, particularly when the tax case is analyzed in depth.
Existing Public Tax Rulings in Georgia Issued by the Ministry of Finance
As of today, the following public decisions/ruling are published by MOF (Non-exhaustive list):
- Taxation (in Georgia) of Income (capital gain) Derived from (sale of) Securities
- Taxation (in Georgia) of sale of Cryptoasset (Cryptocurrency) and Computing Hash Power for Their Mining
- VAT Taxation (in Georgia) of Tourism Services
- On the VAT Tax implication (in Georgia) on the Use by a Taxable Person of a Self-Constructed Building/Structure as a Fixed Asset
- On the Application of Subparagraph “e” of Paragraph 1 of Article 170 of the Tax Code of Georgia (VAT exemption article)
- On the VAT Taxation (in Georgia) of a Barter (Exchange) Transaction Involving the Supply of Immovable Property
- On the Property Tax Application on the Right to Use a Leased Asset
Why Tax Consultant Participation in Drafting Public Tax Rulings of MOF Matters
During the meeting, four draft Public Rulings were presented and discussed with practitioners. Being involved at this stage provides a significant professional advantage.
As a tax consultant participating in these discussions, we are able to:
- Identify ambiguities in draft tax rules
- Provide practical feedback based on real client cases
- Contribute to improving the clarity of tax legislation before it is finalized
This is not only a technical exercise — it is part of the broader tax policy development process in Georgia with participation of private section of tax consulting firms.
However, it shall also be noted that our contribution to the tax policy development process does not necessarily mean that public rulings reflect all of our opinions or that we agree with all parts of the published public decisions. Critical comments provided by us during the consultation process may not always be decisive.
A Unique Advantage for Our Firm and Our Clients
Our involvement in discussions organized by MOF and GRS gives us a deeper and more practical understanding of what is actually meant by the wording of Public Tax Rulings and other tax decisions.
This goes beyond the standard interpretation of written Georgian tax law.
For our clients, this means:
- More precise tax consultation in Georgia based on real regulatory intent
- A better understanding of how Georgian tax authorities are likely to interpret and apply tax rules in practice
- Earlier insight into upcoming changes in Georgian tax law and tax policy
- Improved tax risk management and stronger tax compliance
In many cases, the difference lies not only in understanding what the law says, but also how it is intended to work in practice.
One of the factors that distinguishes our tax consultation services in Georgia is that we understand Georgian tax law not only based on the wording of the legislation, but also from practical experience and the approaches applied by the Georgian tax authorities in practice. Notably, our tax consultant, Gela Barshovi, is a former tax inspector with working experience in the tax field not only in Georgia, but also in Germany and Austria. In simple terms, we understand “the situation inside the kitchen” — meaning that we understand how certain provisions of Georgian tax law may be interpreted in practice, and we are able to critically analyze tax legislation taking into account practical experience and approaches applied by the Georgian Revenue Service (GRS).
You can read Gela Barshovi’s tax-related articles on our website to better understand his views on significant tax matters in Georgia, particularly those relevant to foreigners planning to relocate to Georgia.
Looking for Reliable Tax Consultation in Georgia?
At TPsolution, we combine practical experience in tax consultation, Georgian tax law interpretation, and tax compliance with direct participation in discussions related to tax policy and public tax rulings in Georgia.
If you would like to receive an objective and realistic assessment of your tax situation — rather than an overly optimistic opinion — feel free to contact us. We provide verbal and written tax consultation services in Georgia for businesses, individuals, and foreigners relocating to Georgia.
Our tax consultant, Gela Barshovi, is a former tax inspector with practical experience in Georgian and international taxation.
You can contact us by email at [email protected] or fill out our contact form here: Contact TPsolution