Transfer Pricing in Georgia (2026): What It Is, What Changed, and How to Report

Transfer pricing (TP) ensures related companies price their cross‑border transactions as if they were independent. Georgia has long followed OECD‑aligned TP rules, but starting in 2026, all taxpayers must file a new annex disclosing their international controlled transactions.

Deadline for everyone: April 15 each year for companies with the Estonian profit‑tax model. Reporting is required if your total controlled transactions exceed GEL 500,000 annually.

What is Transfer Pricing? (and why it matters in Georgia)

Transfer pricing governs how related entities set prices for cross‑border transactions—e.g., goods, services, loans, royalties and the use of intangibles—so that profits are allocated where value is created. The arm’s‑length principle requires related parties to price as if they were independent, which is the cornerstone of Georgia’s regime and the OECD Transfer Pricing Guidelines.

Georgia embedded TP rules in its Tax Code (Articles 126–129¹) and a detailed Ministry of Finance Instruction (Decree #423, 2013), which together align Georgia’s framework with the OECD Guidelines where local law is silent.

Who is in scope?

You fall under Georgian TP rules if you are a resident enterprise transacting with a non‑resident related party or a person registered in a preferential (offshore) jurisdiction—even absent equity links in the latter case, TP scrutiny still applies.

Relatedness broadly exists where one party directly or indirectly participates in the management, control, or capital of the other, or where the same person(s) do so for both parties; ownership of >50% is an automatic indicator.

Accepted pricing methods in Georgia

Georgia recognizes standard OECD methods and applies a “best method” rule to select the most reliable approach for the facts: CUP, Resale Price, Cost Plus, Transactional Net Margin (TNMM), and Profit Split.

Documentation expectations (pre‑2026 and continuing)

Historically, Georgian taxpayers had to prepare TP documentation annually and submit it to the Revenue Service within 30 days of request; format typically mirrors an OECD‑style local file. That obligation remains in force alongside the new annual disclosure.

For large deals, Georgia also provides for advance rulings/APAs (legally binding pricing agreements) when a cross‑border transaction exceeds GEL 50 million—a mechanism to gain upfront certainty.

The 2026 Game‑Changer: Mandatory Annual Disclosure via CIT Annex

The legal trigger and what changed

On February 24–25, 2026, Georgia’s Ministry of Finance adopted Order No. 52, amending the tax administration instruction to add a new annex titled “Information on International Controlled Transactions as Provided for in Articles 126–129¹ of the Tax Code of Georgia.”

This annex must disclose each international controlled transaction for the prior calendar year, including the counterparty name, residency, type of relationship, transaction amount, receivable/payable balances, and other specifics.

Who must file the new annex (materiality threshold)

The new disclosure applies if the total amount of international controlled transactions (including gratuitous transactions and year‑end balances) exceeds GEL 500,000 in a calendar year.

Exactly when to file: file the annex with the March declaration for the reporting year just ended, making the deadline April 15, 2026 (for 2025 transactions).

Some professional commentaries also framed the reform more generally as a “new appendix” filed with the March CIT return for internationally controlled transactions, signalling a shift from “upon request” documentation to proactive annual reporting and likely more inspections.

2024–2025 Updates You Shouldn’t Miss

• Latest OECD Guidelines referenced: In October 2024, Georgia amended TP regulations to reference the latest OECD TP Guidelines, modernizing interpretive alignment.
• Financial transactions tightening (from Jan 1, 2025): The same amendment introduced criteria for re‑qualifying certain controlled loans as equity, materially affecting intragroup financing structures.

These updates raise the bar on economic substance and pricing of intragroup finance, which are frequent audit focus areas globally and in Georgia.

What information goes into the new annex?

At a minimum, be ready to capture and report for each controlled transaction: counterparty identity & residency, relationship type, transaction value, outstanding receivables/payables, and other fields defined in the amended instruction.

If your aggregate controlled transactions for the year exceed GEL 500,000, the annex becomes mandatory.

A month‑by‑month compliance timeline (for FY2025 data)

• January–February 2026: finalize your TP local file and reconcile 2025 intercompany data; validate whether your total controlled transactions exceed GEL 500,000.
• By April 15, 2026 (Estonian‑model filers): submit the March declaration with the annex covering 2025 controlled transactions.

Even after filing the annex, keep your full TP documentation ready—in Georgia the Revenue Service can still request the dossier, and you must provide it within 30 days.

Practical compliance checklist (Georgia 2026)

• Map your related‑party network & offshore ties. Confirm whether any counterparties are related under Georgian definitions or are in preferential tax jurisdictions.
• Quantify annual exposure. Sum all international controlled transactions—including gratuitous items and year‑end balances—to test the GEL 500,000 threshold.
• Select and support your pricing method. Use OECD‑aligned methods (CUP, Resale, Cost‑Plus, TNMM, Profit Split) and justify the best method for each transaction cluster.
• Benchmark and analyze functions/risks. Your local file should map who does what, who uses which assets, and who takes which risks—consistent with OECD guidance as referenced by Georgia.
• Prepare the new annex early. Capture required counterparty and deal‑level data in a structured format so that the April submission is plug‑and‑play.
• Review intercompany loans. Check whether any loan could be re‑qualified as equity under the 2024 amendment effective Jan 1, 2025.
• Consider an advance ruling for mega‑deals. For transactions > GEL 50 million, evaluate a binding APA/ruling to reduce uncertainty.

Common pitfalls we’re already seeing

• Misunderstanding the threshold. The GEL 500,000 test looks at total international controlled transactions plus certain balances and gratuitous dealings—not just sales/purchases.
• Missing the regime‑specific deadline. Estonian‑model taxpayers file with the March declaration (April 15); annual profit‑tax filers attach to the CIT return (April 1).
• Treating the annex as a substitute for documentation. The annex is disclosure, not your full TP support—30‑day submission clock still applies if the RS asks.
• Overlooking finance transactions. New criteria may re‑characterize loans as equity from 2025, affecting deductibility and profit allocation.

FAQs: Transfer Pricing in Georgia (2026)

Q1: Who must file the new TP annex?
Any resident enterprise whose aggregate international controlled transactions for the prior year exceed GEL 500,000 (including certain balances and gratuitous transactions).

Q2: What are the 2026 deadlines for 2025 transactions?

• Estonian‑model taxpayers: submit with the March declaration by April 15, 2026.
• Other profit‑tax filers: submit with the annual CIT return by April 1, 2026.

Q3: Do I still need a full TP file if I submit the annex?
Yes. You must maintain TP documentation and provide it within 30 days upon request by the Revenue Service.