Tax Questions for Georgian VASP Models

Corporate profit and distributions

Georgia generally applies a 15% profit-tax rate under its distributed-profit model. The timing and base depend on distributions and specified deemed distributions or non-business payments. Dividends to specified recipients can also carry 5% withholding. Exact treatment requires current advice on the recipient, treaty, structure and transaction.

Service income is not the customer’s asset gain

An exchange spread, custody fee, transfer charge, management fee, listing or technology fee belongs to the company’s business model. Its accounting, VAT/place-of-supply, source and profit treatment should be analysed separately from whether an individual customer’s disposal of a cryptoasset is taxable.

Public Decision No. 201 has limits

The Revenue Service public decision addresses specified VAT and individual income-tax questions around cryptoasset operations and mining. It should not be converted into a blanket exemption for a Georgian company providing regulated services. Read it together with the Tax Code and the actual facts.

Payroll and local substance

Directors, employees, contractors and secondees create payroll, withholding, social, immigration and permanent-establishment questions. The tax structure should agree with who performs the work, who signs contracts and where value is created.

Cross-border groups and transfer pricing

Shared technology, brand, liquidity, management, loans and support services between related parties require written agreements, defensible pricing and allocation of functions, assets and risks. A Georgian VASP should not be left with regulatory responsibility but no economic capacity or revenue.

Customer assets and accounting

Custody, omnibus accounts, principal trading, agency execution, reserves and collateral may have different balance-sheet and revenue consequences. Accounting design should be agreed before the business plan and regulatory projections are finalised.

Tax workstream deliverables

• Entity, contract and revenue-flow map.
• Corporate profit and distribution analysis.
• VAT and place-of-supply questions by service and customer.
• Payroll, director and local-substance review.
• Related-party and transfer-pricing map.
• Accounting and invoicing requirements.
• Open points requiring a ruling or specialist opinion.

CryptoLicense.ge coordinates tax inputs with the regulatory and operating model. Final tax advice and filings are scoped to the facts and responsible specialist.