The Georgian part of an exit from Spain is the easy one. 183 days of presence, registration with the Revenue Service, done — the rules are clear and the authority is fast. The difficult part stays behind: Spanish residence does not end because Georgian residence begins. It ends on Spanish rules, and where both states treat you as resident, a convention from 2010 decides. This article sets out what happens on the Georgian side, what has to be settled on the Spanish side — and where the limit of our competence runs.
Two residences that do not cancel each other out
The common assumption is that reaching 183 days in the destination country takes you out of the country of origin. That assumption is why exits become expensive years later.
In fact two separate tests run. Georgia looks, under Article 34(2) of its Tax Code, at 183 days in any continuous twelve-month period ending in the relevant tax year — rolling, not tied to the calendar year, with residence following for the entire tax year. Spain continues to apply its own rules independently, and there what counts alongside presence is where the centre of your economic interests lies.
Both can answer yes at the same time. For that case the double taxation convention applies — signed in Madrid on 7 June 2010, published in the Boletín Oficial del Estado No. 130 of 1 June 2011 and in force since 1 July 2011 under its Article 29(2). It contains the usual sequence for dual residents: permanent home, then centre of vital interests, then habitual abode, then nationality.
The practical consequence is uncomfortable and cannot be negotiated away: a retained home in Spain and a centre of life that stayed there beat the day counter in Tbilisi. Building the structure without actually completing the move leaves you with two tax liabilities instead of one low one.
Reporting obligations continue while you are resident
The second point at which exits come apart is not a tax but a piece of information.
Modelo 720 covers foreign accounts, securities, insurance policies and real estate. It must be filed by anyone exceeding the EUR 50,000 threshold in one of the blocks as at 31 December of the preceding year; the window runs from 1 January to 31 March. For virtual currencies held abroad there has for some time been a separate Modelo 721.
On the penalty regime a clarification is due, because forums frequently say Modelo 720 was “struck down”. What was struck down were the penalties, not the obligation. In January 2022, in Case C-788/19, the Court of Justice of the European Union held that three elements of the Spanish regime breached the free movement of capital: treating unreported foreign assets as unjustified capital gains not subject to any limitation period, the fine of up to 150 percent, and the flat-rate penalties. Spain then aligned the penalties with those for other informative returns. The filing obligation itself is unchanged.
Add to that automatic exchange of information: Georgia participates in the Common Reporting Standard. A Georgian account opened while you are still resident in Spain is therefore reported there. That is not a problem — it is only a problem when it comes as a surprise.
The sequence that makes the difference
-
The Spanish adviser first, then the move
Year of departure, baja from the padrón, Modelo 030, outstanding reporting obligations, and whether a Spanish return is still due for the year of departure — that belongs settled before you fly. We do not advise on it and do not wish to.
-
Then the Georgian registration
Individual entrepreneur and Small Business Status, personal tax number, address registration. Since an amendment of February 2026 the status takes effect on the day the application is filed; the obligations therefore begin immediately.
-
Build and document the presence
The 183 days are not a form but a fact. Tenancy agreement, entry and exit stamps, ongoing local payments — that is the material your Spanish adviser uses to establish the centre of your life.
-
Apply for the residency certificate only afterwards
It confirms a state of affairs; it does not create one. The application makes sense once the presence for the relevant tax year is actually satisfied — before that it certifies nothing you can rely on.
- Opening the Georgian account before Spanish residence ends Permissible and often practically necessary — but it then falls within Modelo 720 and within the exchange of information. Manageable, if you know it.
- Keeping the Spanish home and renting in Tbilisi Precisely the constellation in which Art. 4 of the convention goes against you — a permanent home in both states, and then the centre of vital interests decides.
- Relying on the day counter alone It establishes Georgian residence but ends no Spanish one.
- Documenting the Georgian side cleanly Registration, address registration, evidence of presence, residency certificate — that is our part, and the part your Spanish adviser needs.
What follows from this
For a Spanish exit, Georgia is an unremarkable destination: a convention since 2011, no listing as a non-cooperative jurisdiction, a fast and predictable registration procedure. The friction does not arise in Tbilisi but in Madrid — and not through any malice of the authority, but through an exit completed on paper and not in life.
Our recommendation is therefore as unspectacular as it is robust: settle the Spanish side with a Spanish adviser before you move. We then build the Georgian half so that it supports their case.
FAQ
Are 183 days in Georgia enough to stop being taxable in Spain?
No, and that assumption is the most expensive error in this whole subject. The Georgian 183 days establish Georgian residence — they do not end Spanish residence. Spain applies its own rules to decide whether you are still resident there, and those include not only a day count but where the centre of your economic interests lies. If you are resident under both systems, the double taxation convention between Spain and Georgia decides which state takes precedence. A full calendar in Tbilisi is an argument for that, but not the only one.
Is there a convention between Spain and Georgia?
Yes. The convention for the avoidance of double taxation and the prevention of fiscal evasion was signed in Madrid on 7 June 2010, published in the Boletín Oficial del Estado No. 130 of 1 June 2011 (reference BOE-A-2011-9527) and entered into force on 1 July 2011 under its Article 29(2). It exists in Spanish, Georgian and English, all three texts being equally authentic. For dual-residence cases it contains the usual sequence — permanent home, centre of vital interests, habitual abode, nationality.
Does Spain treat Georgia as a tax haven?
No, and that is the most useful piece of good news here. Spain’s list of non-cooperative jurisdictions is in Orden HFP/115/2023 of 9 February 2023, most recently amended by Orden HAC/649/2026 of 21 June 2026. In the consolidated version as at 27 June 2026 Georgia does not appear. The special rule that keeps Spanish nationals taxable in Spain beyond their departure when they move to a listed territory therefore does not apply. Check the position as at the date of your own departure all the same — the list has been amended several times since 2023 and several entries have been removed.
Do I have to report the Georgian account in Spain?
For as long as you are tax resident in Spain: yes, if the thresholds are met. Modelo 720 covers foreign accounts, securities and real estate and must be filed where one of the blocks exceeds EUR 50,000 as at 31 December of the preceding year; the filing window runs from 1 January to 31 March. For virtual currencies held abroad there is a separate Modelo 721. The sequence matters: a Georgian account opened while you are still Spanish resident falls within that obligation — and is additionally reported to Spain under automatic exchange of information.
Were the Modelo 720 penalties not struck down?
The penalty regime yes, the filing obligation no — a distinction regularly lost in forums. In January 2022, in Case C-788/19, the Court of Justice of the European Union held that the Spanish penalties were disproportionate and incompatible with the free movement of capital: treating unreported foreign assets as unjustified capital gains not subject to any limitation period, the fine of up to 150 percent, and the flat-rate penalties. Spain subsequently aligned the penalties with those for other informative returns. The obligation to file itself remains fully in force.
Do you advise on Spanish tax law?
No, and we regard that as an important boundary rather than a limitation. We are a Georgian corporate service provider: we set up the Georgian side, run it and document it. The Spanish side — the baja, Modelo 030, the year of departure, reporting obligations, wealth tax — belongs with an adviser in Spain, and before the move rather than after it. What we deliver is the Georgian half of the file in a form your Spanish adviser can use: registration, a tax residency certificate on application, evidence of actual presence.
As at: August 2026. Sources cited: Convention between the Kingdom of Spain and the Republic of Georgia for the avoidance of double taxation, signed in Madrid on 7 June 2010, BOE No. 130 of 1 June 2011 (BOE-A-2011-9527), in force since 1 July 2011 under Art. 29(2); Orden HFP/115/2023 of 9 February 2023 as amended by Orden HAC/649/2026 of 21 June 2026 (consolidated as at 27 June 2026); judgment of the Court of Justice of the European Union of January 2022, Case C-788/19; Tax Code of Georgia Art. 34.
On competence: BAUER GROUP Georgia is a Georgian corporate service provider and does not advise on Spanish tax law. The statements about the Spanish side serve to place the question and to identify what has to be settled with an adviser in Spain; they do not replace that adviser’s review. This article is not tax or legal advice.