What foreign investors, corporate groups and tax advisers should do before the new fee schedule takes effect
Under Ordinance No. 251, amending Ordinance No. 96 of 30 March 2010, the fee for an advance tax ruling from the Revenue Service will rise sharply from 1 January 2027. The amount depends on who is asking.
What Changed
Ordinance No. 251 rewrites item 14 of the Revenue Service’s official schedule of fees – the provision governing the cost of an advance tax ruling issued under Article 47 of the Tax Code of Georgia. Under the revised schedule, which takes effect on 1 January 2027:
- The standard fee for an advance ruling rises to GEL 20,000, payable by companies and all other applicants;
- Resident individuals benefit from a reduced fee of GEL 10,000;
- Tax residency for this purpose is assessed by reference to the calendar (tax) year preceding the year in which the request is filed;
- The statutory processing period remains unchanged at 90 calendar days;
- The new fee does not apply to rulings falling under items 48 and 49 of the same schedule, which are governed separately.
Why It Matters
An advance tax ruling lets a business obtain the Revenue Service’s binding position – agreed with the Ministry of Finance – on how a transaction or reporting obligation will be treated before it happens. For investors structuring acquisitions, real estate deals, cross-border financing or reorganisations in Georgia, it has been one of the more accessible ways to de-risk a transaction in advance. The new fee schedule materially raises that cost, particularly for companies and non-resident individuals, turning the advance ruling into a more deliberate, higher-value decision.
A Narrow Window Before the New Fee Applies
Article 2 of Ordinance No. 251 sets an important transitional rule: the increased fee will not apply to requests submitted before 1 January 2027, provided they follow the procedure in Article 19 of the Instruction on Tax Administration approved by Minister of Finance Order No. 996 of 31 December 2010. In practice, this gives businesses already planning a significant transaction a limited but real window to submit under the current fee.
Practical Recommendations
- Companies and investors whose transactions may require certainty on their tax treatment should assess now whether a request can realistically be prepared and filed before the end of 2026.
- Resident individuals contemplating asset sales, corporate restructurings or cross-border arrangements should build the new GEL 10,000 fee into their 2027 transaction budgets.
- Because the value of an advance ruling depends entirely on the accuracy and completeness of the facts submitted, rushing a request to beat the deadline carries its own risk – a poorly prepared submission is of limited use even at the lower fee.
- Treat this reform as a signal: Georgia’s advance ruling mechanism is being repositioned as a premium, high-value service rather than a routine compliance step.
Looking Ahead
For businesses already in Georgia, and for those weighing it as an investment destination, the lesson is straightforward: tax certainty remains available, but obtaining it is becoming a more deliberate, costlier decision – one that rewards early, well-prepared planning over last-minute requests.
How NOMOS GEORGIA Can Help
Nomos Georgia’s tax practice regularly helps international investors, corporate groups and Georgian companies prepare and submit advance tax ruling requests to the Revenue Service. If your transaction could benefit from securing tax certainty before the new fee takes effect on 1 January 2027, contact our tax team to discuss timing and strategy.
