Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping

Georgia

A. Progress in the implementation of the minimum standard

Georgia has 56 tax agreements in force, as reported in its response to the Peer Review questionnaire. 16 of those agreements, the agreements with Belgium, Finland, France, Iceland, India, Ireland, Israel, Lithuania, Luxembourg, the Netherlands, Norway, Serbia, Singapore, the Slovak Republic, Slovenia, and the United Kingdom, comply with the minimum standard.

Georgia signed the MLI in 2017 and deposited its instrument of ratification on 29 March 2019. The MLI entered into force for Georgia on 1 July 2019. Georgia has not listed its agreements with Armenia, Austria, Bahrain, Denmark, Egypt, Germany, Japan, Kazakhstan, Malta, Poland, Qatar, Saudi Arabia, Switzerland, Ukraine, and the United Arab Emirates. These agreements will therefore not, at this stage, be modified by the MLI. Armenia, Denmark, Egypt, Kazakhstan, Malta, Saudi Arabia, Ukraine and the United Arab Emirates have listed their agreements with Georgia under the MLI.

Georgia indicated in its response to the Peer Review questionnaire that bilateral negotiations would be used for its agreements with Malta and Poland.

Georgia is implementing the minimum standard through the inclusion of the preamble statement and the PPT.1

The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.

B. Implementation issues

As mentioned above, Georgia has not listed its agreements with Armenia, Austria, Bahrain, Denmark, Egypt, Germany, Japan, Kazakhstan, Qatar, Saudi Arabia, Switzerland, Ukraine and the United Arab Emirates under the MLI. Listing the agreements under the MLI or entering into bilateral renegotiations to implement the minimum standard would ensure that the minimum standard could be implemented in those non-covered agreements.

Georgia indicated that it would provide a revised list of agreements under the MLI in 2021 and would list all its agreements in force.

Summary of the jurisdiction response - Georgia

 

	Treaty partners	Compliance with the standard	If compliant, the alternative implemented	Signature of a complying instrument	The alternative implemented through the complying instrument (if not the MLI)	Comments
1	Armenia	No	N/A	No	N/A
2	Austria	No	N/A	No	N/A
3	Azerbaijan*	No	N/A	No	N/A
4	Bahrain	No	N/A	No	N/A
5	Belarus*	No	N/A	No	N/A
6	Belgium	Yes	PPT alone	N/A	N/A
7	Bulgaria	No	N/A	Yes	N/A
8	China (People's Republic of)	No	N/A	Yes	N/A
9	Croatia	No	N/A	Yes	N/A
10	Cyprus*	No	N/A	Yes	N/A
11	Czech Republic	No	N/A	Yes	N/A
12	Denmark	No	N/A	No	N/A
13	Egypt	No	N/A	No	N/A
14	Estonia	No	N/A	Yes	N/A
15	Finland	Yes	PPT alone	N/A	N/A
16	France	Yes	PPT alone	N/A	N/A
17	Germany	No	N/A	No	N/A
18	Greece	No	N/A	Yes	N/A
19	Hungary	No	N/A	Yes	N/A
20	Iceland	Yes	PPT alone	N/A	N/A
21	India	Yes	PPT alone	N/A	N/A
22	Iran*	No	N/A	No	N/A
23	Ireland	Yes	PPT alone	N/A	N/A
24	Israel	Yes	PPT alone	N/A	N/A
25	Italy	No	N/A	Yes	N/A
26	Japan	No	N/A	No	N/A
27	Kazakhstan	No	N/A	No	N/A
28	Korea	No	N/A	Yes	N/A
29	Kuwait*	No	N/A	No	N/A
30	Latvia	No	N/A	Yes	N/A
31	Liechtenstein	No	N/A	Yes	N/A
32	Lithuania	Yes	PPT alone	N/A	N/A
33	Luxembourg	Yes	PPT alone	N/A	N/A
34	Malta	No	N/A	No	N/A
35	Moldova*	No	N/A	No	N/A
36	Netherlands	Yes	PPT alone	N/A	N/A
37	Norway	Yes	PPT alone	N/A	N/A
38	Poland	No	N/A	No	N/A
39	Portugal	No	N/A	Yes	N/A
40	Qatar	No	N/A	No	N/A
41	Romania	No	N/A	Yes	N/A
42	San Marino	No	N/A	Yes	N/A
43	Saudi Arabia	No	N/A	No	N/A
44	Serbia	Yes	PPT alone	N/A	N/A
45	Singapore	Yes	PPT alone	N/A	N/A
46	Slovak Republic	Yes	PPT alone	N/A	N/A
47	Slovenia	Yes	PPT alone	N/A	N/A
48	Spain	No	N/A	Yes	N/A
49	Sweden	No	N/A	Yes	N/A
50	Switzerland	No	N/A	No	N/A
51	Turkey	No	N/A	Yes	N/A
52	Turkmenistan*	No	N/A	No	N/A
53	Ukraine	No	N/A	No	N/A
54	United Arab Emirates	No	N/A	No	N/A
55	United Kingdom	Yes	PPT alone	N/A	N/A
56	Uzbekistan*	No	N/A	No	N/A