There are questions in Georgian tax law that cannot be answered conclusively because no administrative position on them exists — not because nobody has asked, but because the authority’s answers are not published. For exactly that situation the Tax Code provides an instrument: the binding ruling under Article 47. It binds the Revenue Service for as long as you act in accordance with it. It costs a state fee that doubles on 1 January 2027 — and that is already enacted law. This article sets out what it does, what it does not do, and the three features by which you can tell whether your case is one for it.
Two instruments that are constantly confused
The Tax Code provides for two kinds of ruling, and they differ in almost every respect. Anyone searching for “a ruling from the Georgian tax authority” and finding the wrong one is either searching for something that does not exist or relying on something that does not protect them.
| Binding ruling (Art. 47) | Public ruling (Art. 46-1) | |
|---|---|---|
| Who issues it | Revenue Service, in agreement with the Minister of Finance (para. 11) | Minister of Finance |
| On whose application | on the application of a specific person | of its own motion |
| Whom it binds | only the applicant (para. 3) | the tax authority generally |
| Is it published | No — para. 9 places the application under tax secrecy | Yes, in the Legislative Herald |
| State fee | yes, four to five figures in GEL | none |
| What it is for | securing your own specific fact pattern | clarifying the general legal position |
The third row explains an observation many people stumble over: for a great many Georgian tax questions you find no administrative position online. That is not because the questions are new but because the answers are covered by tax secrecy. Anyone writing “the Georgian tax authority accepts X” has either heard it from an adviser who knows it from their own mandate — or is claiming more than they can know.
One consolation remains: under Article 47(4) the Revenue Service may not issue divergent rulings on identical transactions carried out by different persons. That is a consistency duty on the authority, not a right a third party could enforce — but it does mean a ruling given has effects reaching beyond the applicant in practice.
What the binding effect actually covers
The binding effect sits in Article 47(5). That is not pedantry but a common mis-citation: paragraph 6 is regularly given as the source of the binding effect while containing precisely the opposite — the two cases in which the binding effect falls away.
- The facts as stated differ from the actual facts Art. 47(6) — the practically most important ground. What is not in the application is not protected.
- The underlying provision is repealed or amended Art. 47(6) — the ruling protects against a divergent interpretation, not against a change in the law.
- An adverse provision is given retroactive force Art. 47(7) expressly protects transactions carried out under a ruling issued earlier.
The first point is where rulings fail in practice. A binding ruling is not absolution for a business model but an assessment of a described fact pattern. If the model is later adjusted — an additional counterparty, a different form of remuneration, a second line of business — then the question is no longer the one that was answered. The statement of facts therefore belongs in the application with the same care as the legal question: narrow enough to stay true, wide enough to still cover the foreseeable development.
The fee — and why 2027 is a date worth knowing
The state fee is not in the Tax Code but in Government Resolution No. 96 of 30 March 2010 on fees for Revenue Service services. For the binding ruling it provides two rates: a standard rate and a halved rate for natural persons who were tax resident in Georgia in the preceding year.
Both amounts double on 1 January 2027. The decisive point for planning: this is not an announcement and not a draft bill but already stands in the consolidated Resolution — with commencement expressly deferred to 1 January 2027. Nothing further needs to be decided for it to happen.
Two opposing recommendations follow, and which applies depends solely on where you stand:
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You are already resident in Georgia — then it is urgent
You pay the halved rate. That halves rate doubles too. An application that is due anyway should be filed in 2026 rather than 2027 — the clearest saving this article has to offer.
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You are only just arriving — then do the arithmetic
The halved rate presupposes residence in the PRECEDING year. Someone arriving in 2026 pays the full rate in 2026 and would reach the halved rate in 2027 — which by then has already doubled. In that constellation the two effects largely cancel out; what decides is whether you need the protection now.
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You are unsure whether you need one at all
Then do not wait on the fee but settle the prior question first. A written opinion costs a fraction and in many cases answers everything — and where it does not, it tells you so.
We deliberately quote no figure in running text. The fee is an external variable that can be changed by resolution, and an amount in a blog post is exactly the kind of statement that goes stale silently. We state the amount applicable at the time of filing in writing before anyone commits.
How to tell whether your case is one
Three features. They should coincide — if one is missing, you are as a rule buying an expensive confirmation of what already applies.
Substantial amounts. The fee is four to five figures in lari and the professional fee comes on top. For a fact pattern turning on a few thousand euros of tax difference, the ratio is absurd.
No known administrative position. Where the consequence follows cleanly from the statutory text and practice is unambiguous, you do not need a binding ruling but clean documentation. It becomes interesting where a term is left undefined in the law — such as the “currency operations” of Annex 4 to Resolution No. 415, whose reach nobody has settled officially.
Repetition over years. A one-off transaction rarely carries the cost. A business model repeating the same transaction every month almost always does — because the risk multiplies with each year and the ruling does not expire.
What follows from this
The binding ruling is a precise tool for a narrow class of cases: large amounts, an unsettled legal question, lasting repetition. For anything below that it is too expensive and too slow, and a written opinion achieves more than most expect — it answers the question, names the residual risks, and tells you whether the case belongs in the narrow class.
Anyone taking that route should take it in 2026, provided it is due anyway. Not because of manufactured scarcity, but because the doubling of the fee on 1 January 2027 is already enacted and pushing a due application across the year end simply costs twice as much.
FAQ
Who issues a binding ruling — and what exactly does it bind?
Under Article 47(1) of the Georgian Tax Code it is issued by the Revenue Service on the application of a person, for transactions already carried out as well as planned ones. The authority does not decide alone: paragraph 11 requires agreement with the Minister of Finance, and paragraph 13 leaves the procedure to him. The binding effect sits in paragraph 5 — not, as is often cited, in paragraph 6. Paragraph 6 contains only the two grounds on which the binding effect falls away: the actual facts differ from those stated, or the underlying provision is repealed or amended.
What does it cost, and is it true that it is getting more expensive?
The state fee is set by Government Resolution No. 96 of 30 March 2010. It currently sits in the five-figure lari range and is halved for natural persons who were tax resident in Georgia in the preceding year. On 1 January 2027 both amounts double. This is not an announcement that might still fail but is already contained in the consolidated Resolution — with a deferred commencement date. Our fee comes on top and is independent of it; we state the government amount applicable at the time of filing in writing before anyone commits.
Is the ruling published? Can I read other people’s rulings?
No. Article 47 contains no publication requirement, and paragraph 9 places the information submitted with the application under tax secrecy. There is therefore no collection in which to look up how the authority decided a comparable case — which also explains why for many questions no known administrative position exists at all. The publicly accessible instrument is a different one: the public ruling of the Minister of Finance under Article 46-1, published in the Legislative Herald and binding on the authority generally.
Is another taxpayer’s ruling of any use to me?
Not directly — under Article 47(3) it binds only the applicant. Indirectly, though, yes: paragraph 4 prohibits the Revenue Service from issuing divergent rulings on identical transactions carried out by different persons. That is a consistency duty on the authority, not a right a third party could invoke. In practice it means your ruling protects you, and it raises the likelihood that a materially identical case is treated the same way — no more than that.
How long does the procedure actually take?
The statutory period is 90 days. Practitioner reports of considerably longer turnarounds circulate; we have not verified them independently and therefore quote the statutory period rather than an experience figure we cannot stand behind. The planning consequence is the same either way: a binding ruling protects a running fact pattern, it is not a precondition for starting. Making your business model depend on it means leaving it waiting on an authority.
When is an opinion enough and when do I need the ruling?
The opinion establishes whether your structure holds; the ruling removes the residual risk that the authority sees it differently. For manageable amounts and a legal position that follows cleanly from the statute, the opinion is the right and considerably cheaper answer. Three circumstances argue for the ruling, and they should coincide: substantial amounts, a question with no known administrative position, and a fact pattern you repeat over years. If one of them is missing, you are buying an expensive confirmation of what already applies.
As at: August 2026. Provisions cited: Tax Code of Georgia Art. 46-1 (public ruling), Art. 47 (binding ruling, in particular paras. 1, 3, 4, 5, 6, 7, 9, 10, 11 and 13), Art. 297; Government of Georgia Resolution No. 96 of 30 March 2010 on fees for Revenue Service services; Government of Georgia Resolution No. 415 of 29 December 2010, Annex No. 4.
On sourcing: the content of this article rests on the Georgian wording of the Tax Code; the official English translation on matsne.gov.ge is roughly eleven years old and out of date in several places. The doubling of the state fee on 1 January 2027 is taken from the consolidated version of Resolution No. 96. Statements about actual processing times beyond the statutory 90 days we have deliberately not adopted, because they could not be independently evidenced. This article is not tax or legal advice.