New Reporting Obligations for International Controlled Transactions in Georgia

It must be completed by companies whose annual volume of such transactions exceeds GEL 500,000, including the market value of free‑of‑charge transactions and receivable/payable balances. The requirement applies from the 2025 reporting year: for taxpayers under the Estonian CIT model, the Annex is filed with the March CIT return (by 15 April), and for other taxpayers with the annual CIT return (by 1 April of the following year). The Annex covers all cross‑border transactions between related parties, transactions with residents of preferential tax jurisdictions and relevant dealings with permanent establishments. It requires disclosure of information on counterparties, the type and amount of transactions, outstanding balances and the status of transfer pricing documentation. The Annex effectively provides the tax authorities with a map of international controlled transactions and may be used to select taxpayers for audits.