Transfer Pricing in Georgia from 2026: What Changed and Why We Should Be Ready

On 24 February 2026, Georgia's Minister of Finance amended Order No. 996, fundamentally changing the tax reporting landscape for companies engaged in international controlled transactions. The change itself is straightforward: the corporate income tax return must now be accompanied by a new annex, "Information on International Controlled Transactions," which covers counterparty details, transaction types and volumes, outstanding receivable and payable balances, and the preparation status of transfer pricing documentation.

This means the Georgian Revenue Service will, for the first time, receive systematic data on which companies have transfer pricing documentation in place, and which do not. Until now, that information only surfaced during tax audits.

Who Is Affected

The new obligation applies to companies that meet the following two conditions:

1. They conduct transactions with foreign related parties or with entities registered in preferential tax jurisdictions.
2. The total volume of those transactions, including related receivable and payable balances, exceeds GEL 500,000.

Why This Matters

By completing the annex, a company is effectively answering a question: do you have transfer pricing documentation ready, or not? If the answer is no, the Revenue Service now holds a pre-filtered list of companies that engage in international controlled transactions but lack documentation. Selecting audit targets from that list is a matter of routine.

The burden-of-proof implications deserve equal attention. Under Georgian tax law, if a company submits transfer pricing documentation, the burden of proof shifts to the tax authority: it must demonstrate that the pricing does not comply with the arm's length principle. If no documentation is submitted, that burden stays with the company. The difference is substantial.

The 30-Day term

When a tax audit is initiated, the company has 30 calendar days to submit its transfer pricing documentation. Anyone who works in this field knows that this deadline is often not enough to prepare these documentation from scratch.

Transfer pricing documentation is not a form to fill out. It requires a detailed analysis of controlled transactions, processing of financial data, benchmarking against comparable companies using commercial databases such as Orbis and Bloomberg, and a reasoned demonstration of compliance with OECD standards. The database analysis alone can take several weeks.

On top of that, the Revenue Service in practice expects costs to be allocated to each controlled transaction individually and favours local tested parties. For companies with group-level operations, the process becomes considerably more complex.

If a company begins preparing documentation only after an audit has started, there are two possible outcomes: it submits an incomplete document, or it misses the deadline. In either case, the burden of proof remains with the company, a result that can only be avoided through advance planning.

What Needs to Happen Now

Companies with more than GEL 500,000 in transactions with foreign related parties or offshore entities need to do two things: first, determine whether they fall within the scope of the new obligation; second, if they do, begin preparing their transfer pricing documentation now rather than waiting for an audit request.

The 30-day window is not a preparation deadline. It is a submission deadline.

DGN Consulting's tax team handles transfer pricing documentation, market analysis, and representation in tax audits and disputes. If the issues described above apply to your company and you have not yet started preparing, get in touch: contact@dgn.ge