Georgia exchanges financial account information under the Common Reporting Standard (CRS). A Georgian bank account or tax-residency certificate does not provide a blanket exemption from reporting to other countries. The correct treatment depends on the account holder's tax residence, the account or entity classification and the relevant exchange relationship.

What changed and when

The OECD confirms that Georgia began CRS exchanges in 2024. Due diligence for new accounts started on 1 January 2023. Reports generally concern an earlier reporting period, rather than the calendar year in which the information is exchanged.

Financial institutions must distinguish the Georgian reporting deadline from the later exchange between tax authorities. The applicable Revenue Service procedure, reporting year, schema and any official extensions should be checked before filing.

What a bank may need from an account holder

CRS due diligence can require the person's name, address, date of birth, tax-residence jurisdictions and tax identification numbers. Banks also examine whether a self-certification is reasonable in light of their other customer information. A change of address, residence, ownership or control may require an updated declaration.

Depending on the account, reportable information can include account identification, year-end balance or value, and specified income or proceeds. CRS is a financial-account reporting system, rather than a general report of every transfer made through a bank account.

Georgian tax residence is not a privacy shield

A person may be tax resident in more than one country under domestic rules. Obtaining Georgian residence, spending time in Georgia or receiving a Georgian tax-residency certificate does not automatically end residence elsewhere. Applicable treaties and the facts of the person's home, family, work and presence may need to be considered.

The Georgian Tax Code contains the physical-presence test and other tax-residence provisions, including the procedure for qualifying high-net-worth individuals. HNWI tax residency is separate from an immigration residence permit. It should not be advertised as protection from CRS or as permission to omit another reportable tax residence.

Nor does Georgian tax residence mean that every payment from a foreign client is tax exempt. The source and character of income, the activity performed, the taxpayer and any treaty must be assessed separately.

Companies and controlling persons

A company account requires an entity classification. For a passive non-financial entity, due diligence can extend to the natural persons who control it. A Georgian incorporation certificate, nominee director or foreign holding company does not by itself settle the CRS classification or remove controlling-person reporting.

We review the ownership chain, actual activities, income and assets before advising on the self-certification. FATCA is a separate reporting regime and must also be considered where relevant.

Amended CRS and crypto-asset reporting

The OECD has adopted amendments to CRS and a separate Crypto-Asset Reporting Framework (CARF). Their adoption at international level should not be confused with a single automatic commencement date in every country. Domestic implementation, exchange commitments and the reporting period must be verified for the jurisdiction concerned.

A VASP's regulatory registration and AML duties are also distinct from tax-reporting obligations. Businesses should assess each requirement separately instead of assuming that compliance with one system covers the others.

Practical steps before making a declaration

Identify all potentially relevant tax-residence jurisdictions and the dates of any move.
Gather tax identification numbers and residence evidence.
Check the company and controlling-person classifications where an entity holds the account.
Make sure the declaration agrees with the information already held by the bank.
Correct inaccurate information through the institution's procedure and retain the supporting records.

Our team assists with Georgian tax-residence questions, bank documentation and cross-border coordination. We can assess the Georgian position and identify where advice from another country's tax professional is needed.

Official sources

Contact our legal team with the countries involved, the account or entity type and the question raised by your bank.

Common Reporting Standard in Georgia: Bank Reporting and Tax Residency