International Company Status in Georgia for Game Studios and Platforms

International Company status is Georgia's tax regime for IT businesses: 5% profit tax on distributed profit, 5% income tax on salaries and no tax at source on the company's dividends. For a game studio or platform developer with a team in Tbilisi it can cut the tax bill by more than half, but it was written for software and IT services, not gambling. This post covers who qualifies, what keeps the status, and where iGaming B2B firms lose it.

What International Company Status Gives You

Article 23 of the Tax Code defines an International Company as a Georgian enterprise that carries on activities listed by the Government and earns its income solely from them. The status is granted by the Government, and it changes the company's tax as follows.

Profit tax stays on the Estonian model, so nothing is due while profit is kept in the company; distributions are grossed up by dividing by 0.95. The company can also reduce the taxable amount by salaries paid to Georgian citizens and by research and development costs incurred in Georgia (Art. 23(12) and Annex 3 of Government Ordinance No. 619).

Which iGaming B2B Activities Fit the Permitted List

Annex 2 of Ordinance 619 lists the permitted activities: software publishing, including publishing computer games (NACE 58.21); computer programming, IT consulting and related services (62.0-62.09); digital products and software support; website development; web hosting and remote maintenance; software updates; database access; and remote system administration. Each means a service delivered under a service contract.

As of October 2026, gambling appears nowhere in Ordinance 619 or in any of its seven amending ordinances, so there is no exclusion for iGaming. There is no inclusion either, which leaves each revenue line to be tested against the list.

An online operator cannot qualify. Organising games is not on the list, and the status goes only to companies taxed on distributed profit under Article 97(1), while online casinos and sportsbooks are taxed on gaming revenue (Annex 1 Art. 2(3)). Affiliate marketing is not on the list either, which is why affiliate tax in Georgia comes down to the 1% regime or an ordinary LLC.

The Conditions for Keeping the Status

Two years' experience

The company must have at least 2 years' experience in the permitted activity it applies for (Ordinance 619, Annex 1 Art. 2(1)). The experience can be its own, that of the non-resident company it represents in Georgia, or that of partner enterprises owning more than 50% of it. Services provided to clients based or managed in Georgia count toward the 2 years (Ordinance No. 67 of 2021). A studio founded last year with no parent track record has to wait.

Substance in Georgia

Since Ordinance No. 180 of 2021, the company must carry on the permitted activity in Georgia and perform its core income-generating activities here, with adequate staff holding the needed qualifications and adequate operating costs. Core activities are the significant functions that create the economic value, not mainly auxiliary ones. In practice that means a real office and development team in Tbilisi, which is the starting point of setting up an iGaming company in Georgia with staff, an address and a bank account.

The 2% cap on other income

Besides its permitted revenue, the company may receive only income incidental to the permitted activity, up to 2% of permitted revenue in a calendar year, excluding VAT. The Tax Code cancels the status from 1 January of the year a non-permitted activity began (Art. 23(3)), and Ordinance 619 goes further, treating it as revoked from the date it was granted when the cap is breached (Annex 1 Art. 3(4)(b)).

The Supply Permit Still Applies

International Company status is a tax status, not a gambling permit. Under the gambling law, "supply" means providing games and essential products, including RNGs, jackpot and gaming platforms, servers where game results are determined, player databases and management systems, to a Georgian organiser or to a person outside Georgia (Art. 3). It needs the supply permit, which runs for 5 years (Art. 11(1)(l), 11(18)), and a Georgian organiser may not use games or essential products from a supplier without one (Art. 29(4)).

On our reading of Article 3, that brings a Tbilisi studio serving operators abroad inside the regime. A studio supplying operators under the 2026 international permits needs the permit before its client can file, because the operator's application gives the supplier's permit number and the supply contract. The Georgian B2B supply permit and International Company status are compatible: Ordinance 619 expects an applicant whose activity needs a permit to attach it (Annex 1 Art. 2(6)). The gambling law also lets the Minister of Finance ban specific services to operators abroad (Art. 5(4)); we found no such order as of October 2026.

Virtual Zone Person: The Older IT Regime

The Law on Information Technology Zones still offers Virtual Zone Person status: no profit tax on profit from supplying abroad IT the company created, and no VAT on that supply (Art. 3(2)), granted within 10 working days (Art. 5). Since 2021 a Virtual Zone Person cannot be granted International Company status, and a company that moves to International Company status gives up its Virtual Zone status.

The law also says a Virtual Zone Person needs no licenses or permits for its activities (Art. 4(2)). That clause predates the gambling supply permit, and the usual rule is that the later, specific law prevails, but no ruling settles it. We would not rely on Virtual Zone status to avoid the supply permit, and its exemption does not cover operating games or taking bets, which are not IT production.

How to Apply for International Company Status

The application goes to the Revenue Service on the Minister of Finance's form, naming the permitted activity and where the services are rendered, with evidence of the activity and any permit the activity requires (Annex 1 Art. 2(4)-(6)). The Revenue Service checks it within 10 days and can give up to 10 more days to correct defects. It then passes the file to the Ministry of Finance, which proposes it to the Government.

The Government grants the status by ordinance, for an indefinite period, effective from the start of the month in which it is granted (Annex 1 Art. 2(10)-(12)). The ordinance sets no deadline for that final decision. The Revenue Service keeps the register of International Companies, and taking "innovative startup" status later revokes the International Company status (Ordinance No. 420 of 2025).

International Company Status for iGaming FAQ