iGaming Affiliate Tax in Georgia: How Commission Is Taxed

An iGaming affiliate working from Tbilisi earns commission from casinos and sportsbooks abroad, and Georgian tax law can treat that income in very different ways depending on the structure behind it. This post compares the 1% Small Business Status, an ordinary individual entrepreneur, a Georgian LLC and International Company status for affiliate income, and marks clearly where the law leaves an open question.

How Georgia Taxes Affiliate Commission

Affiliate income is commission for marketing services: revenue share, CPA or hybrid fees paid by an operator for players referred. Georgia has no affiliate-specific rule in the Tax Code, so the tax depends on who earns the commission and which regime that person holds.

Commission From Abroad Is Georgian-Source Income

Commission paid by a casino in Malta or Curaçao is not foreign income for an affiliate living in Tbilisi. Under Article 104(1)(c)(c.g) a service counts as delivered in Georgia when the provider and recipient are in different states and the provider is a Georgian resident, unless the provider works through a permanent establishment abroad. Commission earned by a Tbilisi-based affiliate is Georgian-source income.

That matters both ways. It brings the commission inside the Georgian tax base, and it is also what lets the commission sit inside the 1% regime, whose taxable income is Georgian-source income (Art. 90(3)). An individual becomes Georgian tax resident by spending 183 days or more in Georgia in any continuous 12-month period ending in the tax year (Art. 34(2)).

Small Business Status and the Gambling Exclusion

Small Business Status is available only to an individual entrepreneur, not to a company (Art. 88(1)). Holders pay 1% of Georgian-source gross income, rising to 3% from the month turnover passes about €171,900, and lose the status if turnover exceeds that cap in 2 calendar years in a row (Art. 89(2)(a), 90). There are no deductions and losses are not carried forward.

The Government may list activities that cannot hold the status (Art. 88(2)), and it did so in Resolution No. 415 of 29 December 2010. Annex 4 excludes, among others, activities that need a license or permit, consulting, and "gambling business" (სათამაშო ბიზნესი). All 14 amending resolutions to date leave that item in place.

The resolution does not define gambling business. The Tax Code uses the phrase for organisers of games, the businesses players win from (Art. 8(27)). An affiliate organises no games and holds no permit; it sells advertising and referral services, so our reading is that it falls outside the exclusion. The opposite reading is open to the Revenue Service, because an affiliate's commission is often a share of a casino's gaming revenue, and no ruling or guidance settles the point as of October 2026. An affiliate that also advises operators runs into the separate consulting exclusion.

The LLC Route for Affiliates

A Georgian LLC is taxed on the Estonian model. Profit kept in the company is not taxed; profit tax of 15% falls due when it is distributed, along with expenses unrelated to the business, free supplies and representation expenses above the limit (Art. 97(1), 98(1)). The tax is grossed up, so a dividend is divided by 0.85 to find the taxable amount (Art. 97(10)), which makes the tax 15% of the profit used.

Dividends paid to an individual or a non-resident are then withheld at 5% (Art. 130(1)), unless a tax treaty lowers the rate for a non-resident owner, and a Georgian-resident individual owes nothing further on them (Art. 130(3)). An affiliate that reinvests in content, domains and staff pays no profit tax on what it reinvests, which is the main reason to choose a Georgian company for an iGaming business over a sole trader. The company's profit tax period is the calendar month (Art. 135(2)), so even a two-person affiliate LLC needs monthly accounting in Georgia from its first month.

VAT on Affiliate Commission

For VAT, a service to a business is supplied where the business is established (Art. 162¹(3)(a)). Commission paid by an operator established abroad is therefore supplied outside Georgia and carries no Georgian VAT. Registration becomes compulsory once VAT-taxable supplies pass about €34,400 in any 12 consecutive months (Art. 165(1)), and the rate is 18% (Art. 166).

The VAT question comes back once an affiliate sells services to Georgian businesses, such as advertising for a local brand or content work for a Tbilisi agency. Those supplies are made in Georgia and count toward the registration threshold.

Where International Company Status Fits

International Company status gives 5% profit tax on distributions and 5% income tax on salaries, but only to a company whose income comes from the activities in Annex 2 of Government Ordinance No. 619: software and computer game publishing, programming, IT consulting, digital products, website development, hosting and similar IT services delivered under service contracts. Advertising and referral commissions are not on the list, and other income is capped at 2% of permitted revenue.

The status can fit a different company in an affiliate group, one that builds and licenses software for third parties under service contracts and has 2 years' experience and real staff in Georgia. The rules, and the risks for gambling-linked revenue, are the same ones that apply to International Company status for game studios. A Virtual Zone Person is no better a fit, because its exemption covers IT products it creates and supplies abroad, not marketing.

The Advertising Ban Applies Whatever the Structure

Tax structure does not change the advertising rules. Article 8³ of the Law on Advertising bans gambling advertising in any form, including online, and an affiliate site is not one of the exceptions, so Georgia's gambling advertising ban reaches any affiliate content aimed at or reachable by Georgian users. The fine starts at about €3,400. Geo-blocking Georgia and keeping Georgian-language gambling content off your sites removes most of the exposure.

iGaming Affiliate Tax in Georgia FAQ