Estonian Company Run from Georgia: Tax Rules

Many people living in Georgia form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from Georgia. The Tax Code of Georgia looks at where a company is managed: an enterprise whose place of business and/or management is in Georgia is a Georgian enterprise, and a company established under foreign law counts as an enterprise. A resident enterprise is taxed on its distributed profit — a model close to the Estonian one. And the Estonia–Georgia tax treaty leaves a company resident in both countries to an agreement between the two tax authorities. This guide sets out these rules with the official texts, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask a Georgian tax adviser before you form or buy the company. We read the Tax Code of Georgia in its English version, consolidated up to the amendments of 15 October 2026, on matsne.gov.ge, the official legislative herald of Georgia, and the Estonia–Georgia tax treaty and its amending protocol in Riigi Teataja, on 22 October 2026. The English text of the Code is a translation; the Georgian text is the law.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Georgia: the company side

A foreign company is an enterprise. Corporations, companies, firms and similar entities established under the legislation of a foreign country are enterprises (Tax Code of Georgia, Article 21(1)(b)).
Georgian enterprise. A Georgian enterprise is an enterprise whose place of business and/or management is based in Georgia (Article 22(1)); a resident is a resident natural or legal person — a Georgian enterprise or a Georgian organisation (Article 8(20)).
Place of management. It is the place of effective management — where, under the founding documents, the board of directors or other management body exercises managerial functions; if a manager runs the enterprise, it is the manager's place of business or, for a natural person, place of residence, also when the enterprise is in fact managed by that person without an agreement (Article 28(1) and (3)).
What a resident enterprise pays on. The object of profit taxation of a resident enterprise includes its distributed profit, expenses not related to its economic activity, free supplies and transfers, and representation expenses above the limit (Article 97(1)).

An Estonian OÜ is an enterprise for the Code. If you live in Georgia and manage the company from there — as its board member or in fact — Georgia can treat it as a Georgian enterprise. Your Georgian tax adviser answers that with the facts of your case.

In Georgia: the owner side

Resident individual. A natural person who has actually stayed in Georgia for 183 or more days in any continuous 12-calendar-month period ending in the tax year is a Georgian resident for that whole tax year (Article 34(2)).
Income tax. A resident natural person pays income tax on taxable income — the total income earned during a calendar year less the deductions under the Code (Articles 79 and 80(1)).

How a dividend from the Estonian company is taxed in your hands in Georgia is a question for your Georgian tax adviser.

The Estonia–Georgia tax treaty

A company resident in both countries. The competent authorities shall endeavour to settle the question by mutual agreement; until agreement is reached, the company is not entitled to claim the benefits of the Convention (Convention signed in Tbilisi on 18 December 2006, Article 4(3)).
Dividends. Dividends paid by a company resident in one country and beneficially owned by a resident of the other country are taxable only in that other country (Article 10(1), as replaced by the Protocol signed in Almaty on 17 July 2010).
Directors' fees. Fees for a member of the board of a company resident in the other country may be taxed in that country (Article 16).

The Estonian Ministry of Finance's treaty list shows that provisions of the Multilateral Instrument apply to this treaty from 1 January 2023. Whether they change these articles is a question for your Georgian tax adviser. We do not give that ruling.

What to decide before you form or buy the company

Who sits on the management board, and where they live. A manager who is a natural person brings the place of management to their place of residence under Article 28(3).
Where the company is in fact managed. Management in fact counts even without an agreement.
How you take money out. A dividend, a board fee and a salary fall under different articles of the treaty.

What we do on the Estonian side

online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. Georgian tax returns and Georgian tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

The two company forms side by side — both tax distributed profit; capital, share transfer and the profit tax: Estonian OÜ or Georgian LLC.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; Georgian tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in Georgia if I run it from Georgia?

It can be. The Tax Code of Georgia counts an enterprise — including a company established under foreign law — as a Georgian enterprise when its place of business and/or management is in Georgia (Articles 21 and 22); the place of management is where the board exercises managerial functions, or where a natural person who manages the company lives (Article 28). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). Under the Estonia–Georgia tax treaty, the two tax authorities try to settle the residence of a company resident in both by mutual agreement; until then it cannot claim treaty benefits (Article 4(3)). Ask a Georgian tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Georgia: what is taxed where