Expertise Across Jurisdictions

Taxation:

• Corporation Tax: 0% (14% or 20% only when profits are distributed)
• Capital Gains Tax: 20% (in form of income tax)
• VAT: 0 – 20%

Main benefits of the jurisdiction:

• Full participation exemption for dividend income for qualifying holdings
• No withholding tax on outbound dividends paid to non-residents
• No exchange control regulations
• No thin capitalization rules
• Access to EU directives
• Large number of Double Tax Treaties

Types of entities: Private limited company, Public limited company, Limited partnership, General partnership, Commercial association, Nonprofit organization, Sole proprietorship

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: Yes
• Public Registry of Companies: Yes

Time to incorporate: Starting form 24 hours

Taxation:

• Corporate Profit Tax – 15%, payable only when the dividend is distributed. Zero tax possible when using Free Zone companies or Virtual Zones Companies.
• Import Tax – 0%, 5% or 12%
• Excise Tax – depends on the listed products
• Property Tax – up to 1%
• Double Tax Treaties Network – very broad, more than 50 DTTs signed
• Tax year – tax calendar year
• Advance Rulings from tax authorities – available
• VAT registration – voluntary, only obligatory if the turnover of activities subject to VAT exceeds GEL 100,000 per annum
• VAT rates – standard rate: 18%
• Social Security TAX – 0%

Main benefits of the jurisdiction:

• Located in a trade strategic area between Asia and Europe
• Ranked as 7th place in the world for ease of doing business.
• Has successfully adopted the DCFTA that results in having eliminated all customs duties for goods originating in Georgia being imported into the EU
• Free trade agreement (FTA) with China is effective which makes Georgia the second European country (after Switzerland) that has FTA with China
• Offers numerous incentives for the development of the business environment.
• One of the most competitive markets in its region
• Offers three industrial zones, created to cater the needs of specific business sectors and they are to be found in Poti, Kutaisi and Tbilisi.

Main tax incentives that Georgia offers are:

• STC licensed Georgian LLC: exemption from tax for trading performed outside Georgia
• IFC licensed Georgian LLC: exemption from tax for international financial services and holding companies selling shares of foreign entities
• VZC licensed Georgian LLC: exemption from tax for providing IT services outside Georgia
• Free Zone Companies: exemption from any corporate tax and withholding tax.
• Public Registry of Ultimate Beneficial Owners: No
• Public Registry of Companies: Yes

Time to incorporate:  24 hours

Taxation:

• Corporation Tax: none or 9% depending on the activity and legal form
• Capital Gains Tax: none
• VAT: 5% (exempt for international B2B sales)
• No WHT on dividends

Main benefits of the jurisdiction:

• Exemption from corporate and capital gains tax for qualifying activities
• Very low VAT rate (if applicable)
• Very low fixed 9% rate of Corporate Income Tax on profits
• Stable and transparent legal system
• No Personal Income Tax
• Stable and well-developed banking system
• One of the most developed trading and service infrastructure in the world

Types of entities: Offshore company, Free Zone company, Designated Zone Company, mainland Limited Liability Company, Private Foundations.

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: none.
• Public Registry of Companies: none.

Time to incorporate: Starting from 3 days

Taxation:

• Corporation Tax: 19%
• Capital Gains Tax: 18-28%
• VAT: 20% (reduced rate at 5% or 0%)

Main benefits of the jurisdiction:

• Political and economic stability
• Strengthening the image of the company
• High level of ease of doing business (8th jurisdiction in the world)
• Low cost of doing business
• Very good reputation

Types of entities: Private company limited by shares, Private company limited by guarantee, Public limited company, Unlimited company, General partnership, Limited liability partnership, Limited partnership, Sole proprietorship, Community interest company, Charitable incorporated organisation

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: Yes
• Public Registry of Companies: Yes

Time to incorporate: starting from 24 hours

Taxation:

• Corporation Tax: 0% – 10%
• Capital Gains Tax: 0%
• VAT: 0%

Main benefits of the jurisdiction:

• Very low rate of corporate tax that is not imposed in case the company does not do business locally
• Stable and favorable legal system based on the English common law
• Excellent reputation, stable government and special status within the EU

Types of entities: Public company limited by shares, Private company limited by guarantee, Private company limited by shares, General partnership, Limited partnership, Sole proprietorship, Non-resident company, Trust, Foundation

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: Yes
• Public Registry of Companies: Yes

Time to incorporate: Starting from 4 days

Taxation:

• Corporation Tax: exempt for foreign-sourced income.
• Capital Gains Tax: 0%
• VAT: 0%

Main benefits of the jurisdiction:

• Simple and stable taxation and legal system
• Well-developed infrastructure and high quality of support services
• Territorial tax system
• Stable legal and tax system

Types of entities: Private company limited by shares, Private company limited by guarantee, General partnership, Limited partnership, Sole proprietorship.

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: Yes
• Public Registry of Companies: Yes

Time to incorporate: Starting from 24 hours.

Taxation:

• Corporation Tax: 12,5%
• Capital Gains Tax: 33%
• VAT: 23%

Main benefits of the jurisdiction:

• Pro-business stable and country
• economy is the fastest growing in the Eurozone
• one of the lowest Corporation Tax rates in the world -12,5%
• excellent holding company location

Types of entities: Limited liability company, Unlimited company, Investment Fund

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: Yes
• Public Registry of Companies: Yes

Time to incorporate: 1-3 working days

Taxation:

• Corporation Tax: 20%, payable only when dividend is distributed.
• Capital Gains Tax: 10 – 15% 
• VAT: 21% (reduced rate at 12% and 0%)

Main benefits of the jurisdiction:

• Participation exemption regime under which capital gains on share transfers and dividend income is tax exempt;
• The relatively low cost of registration and maintenance of a company
• Possibility to cover the current year profit by losses carried forward

Types of entities: Limited liability company, Joint stock company, European company, General partnership, Limited partnership, Sole proprietorship, Nonprofit organization.

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: Yes
• Public Registry of Companies: Yes

Time to incorporate: Starting from 24 hours.

Taxation:

• Corporation Tax: 12.5%
• Capital Gains Tax: 0%
• VAT: 8% (reduced rate at 3.8% or 2.5%)

Main benefits of the jurisdiction:

• High anonymity, low risk and taxation achieved by setting up private foundations
• Liberal economic policy, efficient authorities and a high degree of legal certainty
• High degree of political continuity and stability
• AAA country rating by Moody’s and Standard & Poor’s
• Stable social, legal and economic order

Types of entities: Limited liability company, Public limited company, Collective/open partnership, Limited Partnership, Individual enterprise, Association, Cooperative, Establishment, Foundations, Trust.

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: No
• Public Registry of Companies: Yes

Time to incorporate: from 2 weeks.

Taxation:

• Corporation Tax: from 15%
• Capital Gains Tax: from 0%
• VAT: 17%

Main benefits of the jurisdiction:

• Europe’s leading financial center
• Political and economic stability
• Rates for individuals are among the lowest in Europe
• Providing clients with safe asset protection
• Center for investment funds

Types of entities: private limited liability company, public limited liability company, Partnerships

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: Yes.
• Public Registry of Companies: Yes

Time to incorporate: approx. 10 days.

Taxation:

• Corporation Tax: from 5% effectively
• Capital Gains Tax: from 0%
• VAT: 18% (reduced rate at 7%, 5% or 0%)

Main benefits of the jurisdiction:

• Possible corporate taxation of 5% (thanks to the shareholders’ refund system)
• No Withholding Tax on Dividends, Interest and Royalties to non-residents;
• Access to EU directives 
• More than 60 Double Tax Treaties.

Types of entities: Limited liability company, Public limited company, General partnership, Limited partnership, Trust, Private Foundation.

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: Yes 
• Public Registry of Companies: Yes

Time to incorporate: starting from 2 days

Taxation:

• Corporation Tax: 20% (25% on profit exceeding €250,000)
• Capital Gains Tax: 0% (in general)
• VAT: 21% (reduced rate at 6% or 0%)

Main benefits of the jurisdiction:

• participation exemption, under circumstances providing for tax exemption for benefits from foreign subsidiaries held by Dutch companies;
• an excellent network of tax treaties with more than 90 countries worldwide;
• an advance tax ruling system
• political and economic stability.

Types of entities: Private limited company, Public limited company, General partnership, Limited partnership, Foundation, Association, Cooperative.

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: yes
• Public Registry of Companies: yes

Time to incorporate: Starting from 1 week.

Taxation:

• different depending on the canton, ranging from approx. 10%
• Capital Gains Tax: 0%
• VAT: 8%

Main benefits of the jurisdiction:

• Great banking infrastructure
• Great reputation
• Free trade and investment policy
• Complete freedom of capital movement
• Stable taxation and legal system
• Well-developed infrastructure and high quality of support services

Types of entities: Private company limited by shares, Private company limited by guarantee, General partnership, Limited partnership, Sole proprietorship.

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: Yes
• Public Registry of Companies: Yes

Time to incorporate: approx. 2 weeks.

Taxation:

• Corporation Tax: from 0%
• Capital Gains Tax: from 0%
• VAT: none.

Main benefits of the jurisdiction:

• Delaware is not considered as offshore jurisdiction
• Beneficial tax treatment for business performed outside the state
• Low annual fees and simple maintenance of a company
• No requirements regarding disclosure of information about the UBO

Types of entities: Limited Liability Company, Corporation, Limited Liability partnership, Limited partnership, General partnership, Delaware statutory trust, Joint venture, Sole proprietorship

Disclosure rules:

• Public Registry of Ultimate Beneficial Owners: No
• Public Registry of Companies: No

Time to incorporate: Starting from 2 days.