Opinions and binding rulings

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 Article 47(6) names the two exceptions: the facts differ from those you stated, or the underlying provision is repealed or amended.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.