Georgia taxes individuals on a territorial basis. Under Article 82(1)(u) of the Tax Code, income that does not come from a Georgian source is exempt even for a Georgian tax resident. Residence depends only on days: 183 or more in Georgia in any continuous twelve-month period ending in the tax year. Most Georgians working in Dubai are therefore non-residents, and their UAE salary is outside Georgian tax either way. What still costs money is Georgian-source income: 5% withholding on Georgian dividends, tax on Georgian rent, and 20% on pension assets returned when you leave for good. The Georgia to UAE treaty’s 0% rates do not help, because the treaty treats only UAE nationals as UAE residents.
This guide is for Georgian citizens living and working in the UAE. It covers the day-count test, the territorial exemption and its limits, the treaty’s nationality condition, and the order to deal with it.
The UAE side is simple. The UAE does not tax employment income, as our guide to what a tax-free salary really means explains, so every question here is about Georgia.
Who Is a Georgian Tax Resident
Article 34 of the Tax Code of Georgia sets the test. Citizenship and a registered address play no part in it.
| Rule | What the Code says | What it means for you |
|---|---|---|
| Article 34(2) | Resident for the whole tax year if actually present in Georgia for 183 days or more in any continuous twelve-month period ending in that year | A Georgian living in Dubai with normal visits home is usually non-resident |
| Article 34(5) | A day of presence counts whatever the length of the stay that day | Arrival and departure days both count |
| Article 34(4)(d) | Time in Georgia for treatment or leisure is not counted as actual stay | Holiday visits may not count toward 183 days; keep evidence of their purpose |
| Article 34(3) | Time spent outside Georgia specifically for treatment, leisure, a business trip or education counts as time in Georgia | This matters for someone based in Georgia, not for someone based in Dubai |
| Article 34(61) | A Georgian citizen whose residence cannot be established in any country is deemed resident if they apply to the tax authority | An option, not an obligation |
The Territorial Exemption
Under Article 79, the income tax payers are resident individuals and non-residents with Georgian-source income. Article 81(1) sets the general rate at 20%. But Article 82(1)(u) exempts income, including gains, received by a resident individual that is not Georgian-source income.
So for UAE salary the residence question hardly matters:
- Non-resident: Georgia taxes only Georgian-source income, and salary for work done in Dubai is not Georgian-source.
- Resident: the salary is still not Georgian-source, so Article 82(1)(u) exempts it.
Georgia is not the only territorial system in this series. Compare our guides for Malaysians and Singaporeans in the UAE.
What Georgia Still Taxes
Article 104 defines Georgian-source income. These are the items that catch Georgians in the UAE:
| Income | Rule | Tax |
|---|---|---|
| Salary for work done in Georgia | Article 104(1)(a): income from employment in Georgia is Georgian-source | 20% under Article 81(1) |
| Freelance services by a Georgian resident to a foreign client | Article 104(1)(c.g): Georgian-source where the provider is a Georgian resident and the client is in another state, unless the provider works through a permanent establishment abroad | Not covered by the territorial exemption |
| Dividends from a Georgian company | Article 130(1): taxed at source when paid to an individual | 5% withholding |
| Renting out a Georgian apartment for residential use | Article 81(2): where the owner claims no deductions | 5% |
| Gain on selling a Georgian apartment or house | Article 82(1)(f.a): exempt if owned for more than two years; otherwise Article 81(3) applies | 0% after two years, 5% before |
| Pension assets returned when you leave Georgia for good | Article 82(1)(b3.c): excluded from the funded pension exemption | 20% under Article 81(1) |
The freelancer trap
Article 104(1)(c.g) is the rule most often missed. A Georgian who spends most of the year in Tbilisi and invoices clients in Dubai is a Georgian resident, and their fees are Georgian-source income because the provider is a Georgian resident. The territorial exemption covers only income that is not Georgian-source, so it does not apply. Someone who genuinely lives in Dubai and does the work there is a non-resident, and the rule does not reach them.
Leaving the funded pension scheme
Contributions to the funded pension scheme are normally exempt. But under Article 82(1)(b3.c) of the Tax Code, the amount of pension assets returned to a participant who leaves Georgia for good under Article 341 of the Law on Funded Pension is excluded from that exemption and taxed at 20%. Weigh that before applying for a refund.
Why the Treaty’s 0% Rates Do Not Apply to You
The Georgia to UAE treaty is often described as one of the most generous in Georgia’s network: Article 10(1) of the treaty text published by the Revenue Service makes dividends paid to a resident of the other state taxable only in that state.
The catch is Article 4(1)(b)(i). For the UAE, a resident individual is an individual who is a UAE national under UAE law. A Georgian citizen living in Dubai is not a UAE resident for the treaty, however long they have lived there. The 0% dividend rule does not apply to them, and the 5% withholding under Article 130 of the Tax Code stays in place.
The treaty’s relief article for residents of Georgia uses the credit method, which is worth nothing where no UAE tax is paid. It does not change the result for salary, because the Tax Code’s territorial exemption already covers it.
The Order to Do This In
- Count your days in Georgia in every rolling twelve-month period, and keep evidence of which stays were for leisure or treatment.
- Keep evidence that your salary is for work done in the UAE: contract, UAE payslips, residence visa, and entry and exit records.
- If you freelance, decide where you actually live. As a Georgian resident, fees from foreign clients are Georgian-source under Article 104(1)(c.g).
- List your Georgian income: dividends (5% at source), rent (5% where no deductions are claimed) and any property sale within two years.
- Check the tax on a pension refund before leaving the funded pension scheme for good.
- Do not rely on the treaty’s 0% rates unless you are a UAE national.
For UAE-side evidence of residence, see our UAE tax residency certificate guide. The UAE also reports account data under CRS, which our guide on how UAE banks report accounts under CRS explains.
What We Could Not Verify
- The treaty’s signing and entry-into-force dates. Georgia’s Ministry of Finance lists the treaty as signed on 25 November 2010 and in force from 28 April 2011; we did not read the ratification notice.
- How the Revenue Service proves the purpose of a stay under Article 34(4)(d), and what evidence it accepts that a visit was for leisure.
- Georgian filing obligations for non-residents with Georgian rent. Where the tenant is not a withholding agent, the owner may have to declare the income; confirm with the Revenue Service.
- The high net worth individual residence status under Article 34(6), which is governed by a ministerial order not covered here.
Frequently Asked Questions
Am I a Georgian tax resident if I live in Dubai?
Only if you are actually present in Georgia for 183 days or more in a continuous twelve-month period ending in the tax year, under Article 34(2) of the Tax Code. Citizenship alone does not make you resident.
Do I pay Georgian tax on my UAE salary?
No. Salary for work done in the UAE is not Georgian-source income. A non-resident is taxed only on Georgian-source income, and a resident’s non-Georgian-source income is exempt under Article 82(1)(u).
Is there a tax treaty between Georgia and the UAE?
Yes, but it treats an individual as a UAE resident only if they are a UAE national. A Georgian citizen living in the UAE cannot use its reduced rates.
Do I pay tax on dividends from my Georgian company?
Yes. Under Article 130(1) of the Tax Code, dividends paid by a Georgian company to an individual are taxed at source at 5%. The treaty’s 0% rule applies only to UAE residents under the treaty, who must be UAE nationals.
What tax applies to rent from my apartment in Georgia?
Under Article 81(2), income from renting out residential space for residential purposes is taxed at 5% where the owner claims no deductions. Otherwise the general 20% rate applies to the net income.
Is the sale of my Georgian apartment taxed?
Not if you owned it for more than two years, under Article 82(1)(f.a). Otherwise the gain is taxed at 5% under Article 81(3).
I freelance for UAE clients from Tbilisi. Is that income exempt?
No, if you are a Georgian resident. Article 104(1)(c.g) treats services by a Georgian resident to a client in another state as Georgian-source income, unless the work is done through a permanent establishment abroad.
Is my pension refund taxed when I leave Georgia?
Yes. Pension assets returned to a participant who leaves Georgia for good are excluded from the exemption by Article 82(1)(b3.c) and taxed at 20%.
Official Sources
- Tax Code of Georgia (Articles 34, 79 to 82, 104, 130), Legislative Herald of Georgia
- Revenue Service of Georgia, Agreement between Georgia and the UAE for the Avoidance of Double Taxation
- Ministry of Finance of Georgia, Double taxation avoidance treaties
Information current as of September 2026. Verify with official authorities before proceeding.
This guide is for informational purposes only and is not tax advice. Georgian and UAE regulations are subject to change. Always verify current requirements with the relevant official authority, or a licensed tax adviser, before proceeding with any filing or transaction.
