Услуги по трансфертному ценообразованию (ТЦ) в Грузии

Transfer pricing services in Georgia 

We offer the following transfer pricing (TP) services: preparation of transfer pricing documentation in accordance with Georgian transfer pricing legislation and the OECD Transfer Pricing Guidelines, development of transfer pricing policies, and ongoing consultations on the application of transfer pricing policies to your intra-group transactions. We specialize in taxation, particularly Georgian tax legislation, transfer pricing, and double taxation agreements. We have twelve years of experience in taxation, including ten years specifically in transfer pricing. Our managing partner, Gela Barshovi, studied transfer pricing legislation in 2012 as a former Georgian tax inspector and was part of an elite group of tax inspectors at the Georgian Revenue Service specializing in transfer pricing.

Transfer Pricing Law in Georgia

Georgia’s transfer pricing law has been in effect since the end of 2013, when Decree No. 423 of the Ministry of Finance of Georgia on transfer pricing was published. Transfer pricing issues in Georgia are regulated by the following legislative provisions:

Tax Code of Georgia:

Articles 126-129(1), in force since January 2011, refer to the transfer pricing regulation.

Transfer Pricing Decree:

Decree No. 423 of the Ministry of Finance, published on December 18, 2013, sets forth the main legislative provisions of Georgia regarding trade plazas. Decree No. 423 refers to the 2017 OECD Trade plaza guidelines and provides the following: Issues not regulated by this decree are governed by the 2017 OECD Trade plaza guidelines.

Transfer Pricing Guidelines of the Georgian Revenue Service.

In addition, the Georgian Revenue Service has published an internal guide on shopping mall issues. The guide contains more detailed explanations regarding the technical aspects of shopping mall inspections, such as how to calculate the interquartile range and much more.

For more information on shopping mall law in Georgia, you can read our article here .

It is noteworthy that without Decree No. 423, Articles 126-129(1) of the Tax Code of Georgia were inactive. The Georgian law on shopping centers has only been fully applicable since the end of 2013, when Decree No. 423 was published.

In Georgia, the practical implementation of the shopping center law began even later, in 2015, when a special department for shopping centers was created within the Georgian Revenue Service (it is worth noting that the founder of our company, Gela Barshovi, was the head of the group in this department from the very first day of its creation).

Preparation of transfer pricing documentation in Georgia

According to the Georgian TP law, transfer pricing documentation must be prepared annually (exceptions may apply to companies with low turnover, which are required to prepare and update this documentation only once every three years).

Deadlines for submitting transfer pricing documentation

Completed TP documentation must be submitted to Georgian tax authorities within thirty days of the request. There are no specific penalties for violating this requirement—only a general fine of ₾400, which applies for each failure to submit the requested document to the SDG. The fine of ₾400 increases in the case of repeated failure to provide the requested document. However, if a Georgian company is required to provide TP documentation within thirty days and fails to do so, the burden of confirming the application of market prices shifts to the company, which may result in additional tax, penalties, and late interest payments, which may exceed the initial ₾400 fine. It is strongly recommended to prepare TP documentation annually and be ready for submission.

Tbilisi-based accounting firm specializes in transfer pricing

As mentioned above, we have unique knowledge in the field of transfer pricing and we are one of the few local Georgian accounting firms in Georgia that are known as experts in the field of transfer pricing.

Transfer Pricing Professional in Georgia

Our founder, Gela Barshovi, an international and Georgian tax expert, is personally involved in each of our transfer pricing projects. We maintain constant communication with the Transfer Pricing Department of the Georgian Tax Service. This communication keeps us abreast of innovative approaches to transfer pricing audits applied by the Georgian Tax Service. We possess in-depth knowledge not only of transfer pricing law but also of transfer pricing practice in Georgia. This is no less important than the transfer pricing law, as many aspects of transfer pricing in Georgia are governed by practical approaches of the Georgian Tax Service, which cannot be found or read in legislative documents. We have a significant advantage: we are familiar with both the law and the applied approaches.

For high-quality transfer pricing services, you can contact us at [email protected] or fill out the contact form here: Contacts  .