Opinions and binding rulings

Two calls, two purposes — and only one of them is advice. The alignment call (15 minutes, free of charge) clarifies which package fits your plan, how the process runs and which documents we need; we answer the same questions in writing without an invoice. The initial consultation costs money because it is work: anyone who describes a fact pattern to us gets back an assessment, not a brochure — someone reads the Georgian statute and holds your case against it. For any question that goes beyond a price enquiry that takes at least half an hour. We therefore decided against the free advisory call and in favour of a fixed-price entry point: €75 for 30 minutes in an online meeting, €150 for 60 minutes or for the written initial assessment. What changes for you: you get an answer instead of a sales hour, and you know beforehand what it costs.

As a Microsoft Teams meeting. After ordering you receive a proposed time and a link; Teams runs in the browser, no installation is needed, and it works from anywhere at no call cost. The telephone is the alternative if you prefer it — you then dial in to us at the agreed time. The reason for that order is mundane: an outbound international call costs more than the fee for the appointment itself in some destinations, and we would rather neither pass that on to you nor price it into what everyone else pays. Screen and audio are the better basis anyway when we look at documents together.

The depth of the analysis, and with it how much weight the answer carries. The written initial assessment (€150, 10 business days) tells you on one or two pages whether your plan holds, where the critical points sit and what still needs clarifying — without an apparatus of citations. The short-form opinion (€690, 10 business days) answers one delimited question with the provision quoted and reasoned. The tax opinion (€1,990, 20 business days) is the complete work: facts, provisions verbatim, application, counter-arguments, residual risks, evidence pack. In a tax audit the opinion carries; the initial assessment carries your own decision on whether the route is worth taking at all.

Because there is more work in it. The short-form opinion answers one delimited question, and 10 business days are enough for that. The tax opinion takes in your entire fact pattern, quotes the provisions verbatim, places the foreign connecting factors, anticipates the counter-arguments of an audit and comes with the evidence pack — that is 20 business days, counted from receipt of complete documentation. If your question is clearly delimited and you need it sooner, the short-form opinion is the shorter route; what it does not give you is the weight the full work carries in an audit.

No. Until August 2026 we credited the opinion fee against a subsequent mandate; not any more. The reason is the same as for the fixed-price entry point: the opinion is a self-contained piece of work, not a deposit on something else. Someone who only needs the answer and then goes on alone has received the same service as someone who instructs us afterwards — and pays the same price for it. The increase from €990 to €1,990 reflects that the credit is gone.

The opinion is our reasoned legal view with citations — robust, checkable, and in a tax audit a very different argument from a recollection of a phone call. It does not bind the authority. The binding ruling (advance ruling) under Article 47 of the Georgian Tax Code is the counterpart: it is issued by the Revenue Service in agreement with the Minister of Finance and protects you under Article 47(5) for as long as you act in accordance with it. Article 47(6) names the two exceptions: the facts differ from those you stated, or the underlying provision is repealed or amended.

It is the larger half of the bill and it is levied by the state, not by us. The fee schedule currently provides for a five-figure lari amount, halved for natural persons who were tax resident in Georgia in the preceding year. On 1 January 2027 both amounts double — that is already enacted law with a deferred commencement date, not an announcement that might still fail. What that means for your case: anyone planning a ruling who also meets the residence condition has two reasons not to leave the application lying until 2027. We tell you the amount applicable at the time of filing in writing before you commit.

The statutory period is 90 days. Practitioner reports of longer turnarounds circulate; we have not independently verified them and therefore quote you the statutory period rather than a number we would like to be true. Plan a ruling as protection for a running fact pattern, not as a precondition for starting — otherwise your business model waits on an authority.

No and no. A binding ruling under Article 47 binds only the applicant (paragraph 3), and the information submitted with the application is covered by tax secrecy (paragraph 9) — so there is no public collection to look things up in. One side effect still protects you: under paragraph 4 the Revenue Service may not issue divergent rulings on identical transactions. 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.

Rule of thumb: 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. We recommend a ruling when three things coincide: substantial amounts, a question with no published administrative position, and a fact pattern you will repeat over years. We tell you in the opinion itself which category your case falls into.

It answers a different question from the tax opinion — the regulatory one: is the planned activity subject to a licence or registration? The Georgian Law on the Securities Market provides for four National Bank licences — brokerage activity, stock exchange, central depository, securities registrar — and contains no express statement about what remains licence-free. Anyone who has to rely on an argument from the contrary is well advised to have it confirmed before building a business model on it.