Georgia: New reporting form for international “controlled transactions”
Form must be filed from 2025 reporting year onward
The Minister of Finance on February 24, 2026, issued Order No. 52, introducing a new reporting form for international “controlled transactions” to the corporate income tax return in Georgia.
The form covers all cross‑border transactions between related parties, transactions with residents of preferential tax jurisdictions, and relevant dealings with permanent establishments (PEs). It requires disclosure of information on counterparties, the types and amounts of transactions, outstanding balances, and the status of transfer pricing documentation.
The form 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, from the 2025 reporting year onward. For taxpayers under the Estonian CIT model, the form must be filed with the March return (by April 15), and for other taxpayers the form must be filed with the annual return (by April 1 of the following year).
Read an April 2026 report prepared by the KPMG member firm in Georgia