Transfer Pricing (TP) Services in Georgia (the country)
Transfer Pricing Services in Georgia
We offer the following Transfer Pricing Services: Preparation of Transfer Pricing documentation in accordance with Georgian Transfer Pricing law and OECD TP guidelines, the setting up of a Transfer Pricing policy, and ongoing consultations regarding the application of a Transfer Pricing policy on your intra-group transactions. We specialize in taxation, particularly in Georgian tax law, Transfer Pricing, and double taxation agreements. We have twelve years of experience in taxation including ten years of experience specifically in Transfer Pricing. Our managing partner, Gela Barshovi, became familiar with Transfer Pricing law in 2012, as he is a former tax inspector of Georgia and he was a member of an elite group of tax inspectors at the Georgian Revenue Service who specialize in Transfer Pricing.
Transfer Pricing Law in Georgia
Georgian Transfer Pricing law has been in force since the end of 2013 when the Transfer Pricing Decree #423 of the Ministry of Finance of Georgia was published. The following legislative norms regulate Transfer Pricing issues in Georgia:
The Georgian Tax code:
Articles 126-129 (1) in force since January 2011 refer to the TP decree.
The Transfer Pricing decree:
Decree #423 of the Ministry of Finance, which was published on 18th December 2013, provides the main TP legislative norms of Georgia. Decree #423 refers to the OECD TP guideline of 2017 and stipulates the following: The issues that are not regulated by the mentioned decree shall be regulated by the OECD TP guideline of 2017.
The Transfer Pricing guideline of the Georgian Revenue Service
In addition, the GRS has published an internal manual regarding TP issues. The guideline provides more detailed explanations regarding the technical part of TP inspections. For example, how to calculate the interquartile range, and much more.
For more information about TP law in Georgia, you can read our article here.
Notably, without decree #423, the articles 126-129 (1) of the Georgian tax code were inactive. The TP law of Georgia has only been fully applicable since the end of 2013 when decree #423 was published.
The practical application of TP law in Georgia started even later; in 2015, when the special TP division at the GRS was created (it is worth noting that our company’s founder, Gela Barshovi, was a group leader in this TP division from the very first day of its creation).
Preparation of Transfer Pricing documentation in Georgia (the country)
According to Georgian TP law, Transfer Pricing documentation should be prepared each year (exceptions might apply to low turnover companies that have the obligation to prepare and renew this documentation only once every three years).
The Due Date for Submission of Transfer Pricing documentation
Completed TP documentation should be submitted to Georgian tax authorities within thirty days of the request. In case of breaching this requirement, there are no special penalties applicable – only a ₾400 general penalty that applies in each case of not submitting the requested document to the GRS. The ₾400 fine increases in case of repeated failures to submit the requested document. However, if the Georgian company has an obligation to submit TP documentation within thirty days and does not do so, the burden of proof about the application of market prices is shifted to the mentioned company, which, as a result, might cause additional tax, penalties and late payment of interest that might result in a greater amount than the original ₾400 fine. It is strongly suggested to have TP documentation prepared each year, ready for submission.
Tbilisi-based accounting firm specializes in Transfer Pricing
As mentioned above, we have unique knowledge in Transfer Pricing, and we are one of extremely few local Georgian accounting firms in Georgia that are renowned as experts in the field of Transfer Pricing.
Transfer Pricing professional in Georgia (the country)
Our founder, Gela Barshovi, who is an international and Georgian tax expert, is always personally involved in each of our Transfer Pricing projects. We have constant communication with the Georgian Revenue Service’s Transfer Pricing division. Such communication constantly keeps us updated on innovative approaches regarding TP audit applicable at the GRS. We possess deep knowledge of not only Transfer Pricing law but also the TP practice applicable in Georgia, which is no less important than the TP law because many aspects of Transfer Pricing in Georgia are regulated by the practical approaches of the GRS that you cannot find and read in the law documents. We have the important advantage that we are familiar with both the law and the approaches used.
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