Create a company in Cyprus — or move your company from Georgia

A Georgian company pays nothing on profit it does not distribute. Not a reduced rate — nothing, indefinitely, with no deemed-distribution rule waiting at the end of it. If you are reinvesting everything you earn, Georgia beats Cyprus outright and no honest page can tell you otherwise. What follows is the case that survives that admission: the single market, an EU VAT number, euro-area banking, and a regime that does not move by government ordinance.

Updated for 2026 Cyprus tax law and regulations.

From Georgia to Cyprus with one provider, from the first filing to the last

Sumly is the one-stop, fully digitalized route for moving a business from Georgia to Cyprus and running it from the day the company exists. We incorporate, open the books the moment you order, prepare every Cyprus return box by box, and deliver the tax residency and non-dom application as a single fixed-price service. One provider, one dashboard, prices published in advance — rather than a law firm for the incorporation, an accountant for the ledger, and no one at all for the part that spans two tax systems.

This is Sumly — and what we actually do for you

Sumly is the fully digital provider for founders moving a company to Cyprus. You do not need to learn Cypriot company law, find a local auditor, or work out which form goes where. You get in touch, and we do the rest.

And we stay with you on both sides of the move. The Cyprus side we own outright. For the side you are leaving, we put you straight in front of an adviser or lawyer from our network who works on exactly your problem — company law, exit taxation, inheritance, employment — and we hold the thread between them and us. One point of contact for the whole move, however many specialisms your case turns out to touch. If your case is simple, we do all of it for a fixed price.

Part 1: What leaving actually costs you

Your home country does not let go the moment the plane does. What still runs after you have left, and in which order it has to be handled.

Does Cyprus actually cut a Georgian founder's tax bill?

Only in one narrow case, and probably not yours. Start with what Georgian law actually does, because it is unusual and most English-language pages describe it wrongly.

The object of profit taxation for a Georgian resident enterprise under article 97(1) is the distributed profit, together with expenses unrelated to economic activity, free supplies of goods, services or funds, and entertainment spending above the statutory limit. That is the complete list. Profit that is earned, retained and put back into the business is not an object of taxation at all — there is no time limit on holding it and no rule that deems it distributed after some number of years. A Georgian company that earns GEL 5,000,000 and distributes nothing pays zero.

Cyprus, like every EU member state, taxes company profit as it accrues, at 15% from tax year 2026. So for a founder who is compounding inside the company, the comparison is 15% against nothing, every year, and the gap widens with time. Say it plainly: on tax alone, that founder should stay in Georgia.

The picture changes only when money leaves. And here is the trap.

Financial institutions sit outside all of this: banks, credit unions, microfinance organisations and loan providers are taxed at 20% on an accrual basis under articles 97(12) and 98(4), which is worth knowing if that is your sector, because none of the reasoning above applies to you.

What do Georgia's small-business regimes cost, and who can use them?

Very little, which is the second half of the concession. An entrepreneur natural person with Small Business Status pays 1% of taxable income, rising to 3% from the beginning of the month in which gross income from economic activity exceeds the ceiling and running to the end of that calendar year. The ceiling is GEL 500,000 of gross income per calendar year, or GEL 700,000 for wine-tourism and agro-tourism operators. Note the grace almost every competitor page gets wrong: a single year over the ceiling costs you 3% for the rest of that year, not the status. It takes two consecutive years above it for the status to be revoked from the start of the following year.

Filing is monthly, with the income tax declaration and payment due by the 15th of the month following the reporting month, rolling to the next working day where that falls on a non-working day. Below that sits Micro Business Status: a natural person using no hired labour whose gross receivable income does not exceed GEL 30,000 a year pays no income tax at all.

One honest gap. Article 88(2) lets the Government, in agreement with the parliamentary Financial-Budget Committee, prohibit specified activities from Small Business Status, and it is widely repeated online that consultancy and several licensed professions are on that list. The statutory power is beyond doubt; the ordinance itself is what decides whether a consultant or agency owner pays 1% or the general rate, and we were not able to retrieve it. We are not going to print a list of excluded professions we have not read. Check your own activity code with the Revenue Service before you plan around 1%, because for the exact reader this page is written for, that single question is worth more than everything else on it.

Do Georgia's IT regimes beat the Cyprus IP Box?

On the face of the statute, yes — and that comparison deserves to be made honestly rather than dodged.

A virtual zone person is a legal person engaged in information technologies and holding the corresponding status, and profit earned from the supply, outside Georgia, of information technologies developed by that entity is exempt from profit tax. Zero, not a reduced rate. Two limits are on the face of the text and they matter: the software must be developed by the virtual zone entity itself, and it must be supplied outside Georgia. Software developed elsewhere and resold does not qualify, and supply into the domestic market does not qualify. Dividends out still bear the ordinary 5% withholding, because the exemption reaches the profit tax and not the dividend tax. Who grants the status and by what procedure is not set out in the Tax Code, and we could not verify it from an official source, so treat "how to apply" as a question for the Revenue Service.

An international company is a Georgian enterprise carrying on activities defined by government ordinance and earning income solely from them. Its profit tax rate is 5%, with the gross-up computed by dividing by 0.95 rather than 0.85, employment income taxed at 5% instead of the general 20%, and dividends neither taxed at source nor included in the recipient's gross income. It cannot be established in a free industrial zone, and performing a non-permitted activity cancels the status retroactively to 1 January of the year that activity began. The list of permitted activities is a matter for a government ordinance we did not retrieve, so we describe the regime and not its scope.

Against that, the Cyprus IP Box brings qualifying income to an effective 3% from tax year 2026. Three per cent is a very good number in Europe and a poor one against zero. The distinction that actually matters is not the rate but what the regime is made of: the Cyprus IP Box is a statutory regime inside the EU's nexus framework, while the Georgian reliefs are creatures of government ordinance, and ordinances move faster than statutes and far faster than directives. If you are building a ten-year business, you are choosing between a lower number and a more predictable one. That is a real trade-off and reasonable founders land on both sides of it.

Does Georgia tax you for leaving?

It does not, and the proof here is stronger than the usual absence-of-evidence argument. Article 6 of the Tax Code sets out an exhaustive list: the national taxes are income tax, profit tax, value added tax, excise and import duty, with property tax as the only local tax. Six taxes in total. There is no net wealth tax, no separate inheritance tax, no gift tax, no social security tax and no exit tax, because none of them appears in a list that articles 6(3) and 6(4) make closed.

The structure of the profit tax reinforces it. Because only distribution triggers a charge, an unrealised gain sitting inside a Georgian company has never been within the charge, so emigration has nothing to accelerate. And when the company is unwound, a payment that does not exceed the partner's contribution to capital is expressly not distributed profit under article 98¹(2)(a) — contributed capital comes back untaxed, and only the surplus above it is a taxable distribution. There is also relief on the way out for real property: the gain is exempt where real estate is transferred to a partner natural person in exchange for their share on liquidation or capital reduction, provided more than two years have passed since the share was acquired.

Gifts and inheritance are handled inside the income tax rather than by a separate levy, and property received by first and second line heirs — spouse, children, grandchildren, parents, siblings, nieces and nephews — is fully exempt. Third and fourth line heirs are exempt up to GEL 150,000 in a tax year, and the rate applying to the excess is taxed as income; we did not find an express rate provision for that head, so we do not quote one. The point for a founder is simple and it cuts against the move: your family inherits tax-free in Georgia, and Cyprus is not solving a problem you have.

Do Georgian CFC rules follow a Cyprus company?

No, because there is no CFC regime to follow it. The word controlled appears in the Tax Code only in the transfer-pricing sense: article 127(4) makes any transaction between related persons a controlled transaction, and article 127(5) makes any transaction between independent persons an uncontrolled one. Chapter XVII requires taxable profit on controlled transactions to accord with the arm's-length principle, with methods and documentation set by order of the Minister of Finance, and a breach feeds back as a deemed distribution under article 98²(b) — the adjustment becomes distributed profit and is taxed at 15% on the grossed-up base. That is the mechanism that stops a Georgian company shipping profit to a Cyprus affiliate untaxed, and it is a live compliance obligation rather than a theoretical one.

There is a related trap worth knowing. Transfer-pricing rules also apply where a Georgian enterprise transacts with a resident of a country with preferential tax treatment, whether or not the parties are related — such a transaction is a controlled transaction by definition. Georgia does not use a blacklist for this; it uses a substantive test in article 98³(5). A country is preferential if a legal person is exempt from profit tax there, or if no profit tax is imposed on profit gained or distributed, or if the profit tax rate does not exceed one third of the Georgian rate. One third of 15% is 5%. Cyprus at 15% is three times that threshold and is comfortably outside the definition, so a Cyprus company is not caught.

And here is the direction of travel nobody selling this move mentions. Georgia has no CFC regime and no exit tax; the European Union has both, harmonised across every member state by articles 5, 7 and 8 of the Anti-Tax Avoidance Directive. Moving into an EU member state does not escape those rules. It acquires them. That is a real and permanent consequence of the move and you should hear it from us rather than discover it in year three.

When does Georgian tax residency end?

The moment you stop meeting a day count — and Georgia is genuinely the simplest of the departure jurisdictions we write about. A Georgian resident for the entire current tax year is a natural person who has actually stayed in Georgia for 183 or more days in any continuous twelve-calendar-month period ending in that tax year, or who was abroad in the public service of Georgia. There is no domicile test. There is no centre-of-vital-interests limb in Georgian domestic law. A house, a family and a business in Tbilisi do not, on their own, keep you resident the way they would in Serbia or Armenia.

Two counting details decide real cases. A day of actual stay is any day on which you were in Georgia irrespective of the length of the stay, so part-days count in full. And article 34(3) works against a departing founder rather than for them: time spent outside Georgia specifically for treatment, leisure, a business trip or education still counts as stay in Georgia. Someone who is really based in Tbilisi and merely travelling a great deal does not shed residence by adding up airport days. Article 34(4) runs the other way for people who are in Georgia in transit, or purely for treatment or leisure, or under diplomatic or international-organisation status.

The provision that makes planning easy is article 34(8): residency status is established for each tax period, and the days that made you resident in a previous period are not taken into account in establishing status in later ones. Residence does not carry over. Each year starts clean. There is consequently no deregistration procedure to complete — you simply stop meeting the count, which is why Georgian founders sometimes assume the same is true everywhere and get an unpleasant surprise elsewhere.

What you will need is a tax residence certificate from the Revenue Service for the receiving side of the move, obtained through the rs.ge portal, which the Revenue Service runs as the single channel for declarations, taxpayer registration and certificate requests. We could not retrieve an official page setting out the application form and procedure, so ask the Revenue Service directly rather than relying on the commercial pages that rank for that query.

Two discretionary routes into Georgian residency exist and founders meet them: article 34(6) allows residency to be accorded to a high net worth individual under a procedure determined by the Minister of Finance, and article 34(6²) allows it to be granted to a foreign natural person in cases the Minister defines. The thresholds and conditions live in ministerial orders we did not obtain, so we describe the doors without measuring them.

Will your Cyprus company become a Georgian enterprise?

If you run it from Tbilisi, yes — and Georgia's drafting is more explicit than almost any comparable statute. An enterprise is Georgian where its place of business and/or management is based in Georgia. Note the and/or: either limb is enough.

Article 29(1) then defines the place of management as the place of effective management, meaning the place where, under the founding documents, the board or other management body exercises managerial functions — regardless of where the top controlling bodies sit or where income is received. And article 29(3) closes the obvious workaround: where an enterprise is managed by a manager acting under an agreement or a resolution of appointment, the place of management is the place of business of the managing enterprise or the place of residence of the managing natural person, and the same rule applies where the enterprise is actually managed by another person without any agreement or resolution at all.

Read that against article 22(1). A Cyprus Ltd whose sole director and real decision-maker lives in Tbilisi has its place of management in Georgia, is therefore a Georgian enterprise, and is taxed in Georgia under the distributed-profit system on its worldwide profit. The treaty offers no escape: article 4(3) of the Georgia–Cyprus agreement deems a dual-resident company resident only of the state of its place of effective management, with no mutual-agreement fallback, and that is the same place.

This is the single greatest execution risk in the corridor, and a Georgian founder's instincts will be wrong about it, because Georgian practice trains you to believe that nothing bad happens until money moves. Here, getting management substance wrong makes the Cyprus company a Georgian taxpayer while it is also a Cypriot one. What protects you is unglamorous and entirely ordinary: a board that genuinely decides, meetings held and minuted on the island, strategic direction and material commitments approved there, and a paper record that matches the reality. Our guide to nominee directors in Cyprus is honest about what a nominee does and does not fix.

What does the Georgia–Cyprus treaty give you?

An unusually generous instrument, and it is the reason a Cyprus layer can be added over a Georgian business at almost no tax cost. The agreement was signed in Tbilisi on 13 May 2015 in Georgian, Greek and English, all equally authentic, with the English text prevailing on any divergence, and the Ministry of Finance records it as in force from 4 January 2016.

Those are not our numbers. The Georgian Ministry of Finance publishes its own treaty table, and the Cyprus row reads permanent establishment nine months, dividends 0%, interest 0%, royalties 0%. Against a 5% domestic dividend withholding, a Cyprus parent over a Georgian operating company extracts profit more cheaply than a Georgian parent would.

Article 12(2) deserves a sentence of its own, because it is where software companies live: royalties expressly include payments for computer software, and article 12(1) leaves them taxable only in the recipient's state. For a Georgian development company licensing into a Cyprus group, or the reverse, the withholding question simply does not arise.

For individuals, article 4(2) gives the familiar ladder: permanent home, then centre of vital interests, then habitual abode, then nationality, then mutual agreement. Article 4(1) defines residence by reference to domicile, residence, place of registration, place of management or a similar criterion, and excludes a person liable to tax in a state only on income sourced there.

Can you move money out of Georgia?

Freely, and the National Bank says so as a description of the system rather than an aspiration. Georgia runs a floating exchange rate alongside free capital mobility as deliberate policy: with inflation targeting and free capital mobility it is necessary to have a floating exchange rate regime, and the rate is determined by market demand and supply rather than administered. The National Bank's monetary policy framework describes no restriction on moving capital, on convertibility or on transfers abroad. Funding a Cyprus company from Georgia is a banking task, not a permissions task.

On banking itself we are going to be disciplined, because this is where relocation marketing usually stops being truthful. We found no official Georgian or Cypriot source describing correspondent-banking difficulty or account refusals for Georgian principals, so we assert nothing about it. What can be said, because it is a matter of legal architecture and is checkable, is this: Georgia is not an EU member state, not in the euro area, not in SEPA by membership, and not in the EU VAT system or VIES. The lari is a freely floating and freely convertible currency — but it is not the euro, and a Georgian bank account is not a euro-area IBAN inside the single market. That is an argument about what an account is and what it connects to. Sumly helps founders get banking and EU payments sorted, and no honest provider will promise you a particular bank's decision.

What happens to your pension and social contributions?

Georgia has no social security tax at all — look again at the six taxes in article 6. What exists instead is a funded pension scheme under the Law on Funded Pension, administered by the state pension fund, and it contains a departure provision that no competitor page in this corridor mentions.

The Tax Code exempts from income tax the sum corresponding to pension assets to be returned to a participant of the funded pension scheme on the ground of his or her leaving Georgia for good, under article 34¹ of the Law on Funded Pension. A participant who leaves permanently can have their pension assets returned, and the return is free of Georgian income tax. Contributions to the individual account and the benefits accrued on them are likewise exempt.

Two honest limits. We verified the existence and the tax treatment of that refund through the Tax Code's own cross-reference, but we did not retrieve the Law on Funded Pension itself, so we cannot tell you the procedure, the evidence required or the conditions for establishing that you have left for good. Nor do we print contribution rates, which are widely quoted online and which we could not confirm from the statute. Get the Law on Funded Pension before you plan around either. Once you are working in Cyprus, the ordinary position is that you insure where you work, and Cyprus social insurance and GeSY apply to a director drawing a salary there.

What happens to the existing Georgian company?

Keeping it is a serious option here, more so than in most corridors.

Route one — keep it as a Georgian subsidiary of the Cyprus parent. Nothing is triggered by the change of ownership, and the company continues under the distributed-profit system, paying nothing until it distributes. Dividends up to the Cyprus parent are 0% under treaty article 10(1) against a 5% domestic rate under article 130(1), which withholds 5% on dividends paid to a natural person or a non-resident enterprise. Intra-group pricing falls under Chapter XVII, with mispricing recharacterised as a deemed distribution. This is a genuinely cheap structure to run, and for a founder adding a Cyprus layer for EU access rather than for tax, it is usually the right answer.

Route two — wind it up. The Law on Entrepreneurs sets the clock, and the sequence is worth having in front of you:

The taxpayer-favourable part is real: if the Revenue Service does not respond within its window, the entity is considered to have no tax liability, and silence clears you rather than stalling you. The awkward part is that article 86(1)'s five-month distribution lock and article 88(1)'s four-month completion deadline do not sit comfortably together on the face of the statute, so we present both rather than pretending to reconcile them. The practical route to a fast wind-up is the auditor's report plus the court decision that shortens the lock to three months. Budget three to five months, and remember that a wound-up company can be revived by a three-quarters majority of the votes cast, provided distribution among the partners has not begun.

Part 2: What Cyprus gives you

This is the straightforward half, and the half we build end to end. What you actually get on the other side.

What does the Cyprus side actually look like?

One flat corporate rate, a shareholder position that is unusually good for an arriving foreigner, and a compliance calendar that is heavier than Georgia's. A Cyprus limited company pays 15% on taxable profit with no bands, and qualifying intellectual property comes down to an effective 3%. On the personal scale, Cyprus taxes salary and other employment income from 0% to €22,000 rising to 35% above €72,000, which is the part of the system a founder on a Cyprus payroll meets first. VAT registration bites above €15,600 of turnover, at a standard rate of 19%.

The shareholder leg is where Cyprus is strong for a Georgian arrival. A Cyprus tax resident who is not domiciled in Cyprus pays no Special Defence Contribution on dividends for 17 years and no income tax on them, leaving GeSY at 2.65% on income up to €180,000 a year. A domiciled shareholder, by contrast, would pay 5% on dividends from 2026 profits. Cyprus levies no net wealth tax and no inheritance tax — which, to be fair, is also true of Georgia. Both positions are set out at length in Cyprus non-dom status, with the wider picture in Cyprus tax benefits for foreigners.

Set against that: a Georgian resident individual pays no income tax on income that is not Georgian-source, with no remittance condition, no ceiling and no subject-to-tax backstop. A founder living in Tbilisi and earning through a foreign company pays nothing on that income in Georgia. There is no version of the Cyprus personal position that beats zero, and we are not going to construct one.

How does a Georgian founder become Cyprus tax resident?

Through 183 days, or through the 60-day rule, which got easier in 2026. Four conditions now apply after the fifth was removed from the 60-day rule: at least 60 days in Cyprus, no more than 183 days in any other single state, a business, employment or office in a Cyprus tax-resident person held through the year, and a permanent home in Cyprus that you own or rent. The dropped condition was "not tax resident anywhere else", and that removal is useful in a corridor where a founder may still be counting Georgian days in the transition year.

The office the third condition asks for can be a directorship in your own Cyprus company, so incorporation and residency advance as a single project. On immigration: the Yellow Slip is a registration certificate for EU citizens exercising free movement, and Georgia is not an EU member state — so it is not the Georgian route and we promise nothing about it. Georgian founders use the routes open to third-country nationals; we run the paperwork that belongs to us and bring in immigration specialists where a file needs them. Day counting and the certificate itself are in the Cyprus 60-day rule.

Why do people choose Cyprus over other tax havens?

Because it is a country people want to live in, and most of the low-tax alternatives are places people merely tolerate. For a Georgian reader the tax argument has already been conceded, so everything below has to stand on its own — and it does.

Violent crime is among the lowest in the European Union. The island runs in English across business, banking, contracts and professional services, which removes the single largest friction of moving anywhere else in Europe. There are people from every corner of the world here already, which means no arriving founder is the only foreigner in the room. Business and real estate are booming. The state is open to people who want to trade rather than treating commerce as something to be licensed first. Groceries — meat, fruit and vegetables — are affordable. And the coast: a Cyprus winter still leaves you an afternoon at the beach, while the summers are the ones people fly across the world to book.

The Georgian case for Cyprus, honestly stated, has five parts and not one of them is a rate:

1. EU membership and the single market. A Cyprus company is an EU establishment and can sell, contract and establish across the union from the inside. A Georgian company cannot. For a founder whose growth depends on European customers, this is the whole argument.
2. An EU VAT identification number, visible in VIES. European business buyers reverse-charge against a VIES-visible number as routine. A Georgian supplier sits outside that machinery, and every EU buyer's finance team handles the invoice as an exception. Deals are lost to that friction quietly, and nobody writes to tell you why.
3. A euro IBAN inside the euro area. Again a statement about what an account is, not about who gets one.
4. Substance that European counterparties accept. An EU-incorporated, EU-audited entity clears jurisdiction filters in procurement and due diligence that a Georgian entity fails on category rather than on merit.
5. Permanence. Georgia's best regimes are the ones most exposed: international company activities, the small-business exclusions and virtual zone status are all matters for government ordinance rather than statute, and ring-fenced preferential regimes are exactly what international tax pressure targets. Building a ten-year business on a 0% status is an exposure to a policy decision, not to a rate. Cyprus moves within the EU framework — slower, more consultatively, with transition periods — and for a founder planning an exit five years out that predictability is worth money.

The structural version of the pitch is the honest one, and it is not "save tax". It is this: because the treaty is 0/0/0 and gains on shares are residence-only, a Cyprus holding above a Georgian operating company gets you EU access without giving up the Georgian tax position on the trading company. Subject, always, to real Cyprus substance and to the principal purpose test.

Can a Georgian e-commerce brand sell through Cyprus?

Yes, and for a store the single-market question usually dwarfs the tax one. A Georgian company is a third-country seller into the EU: customs formalities, import VAT and none of the union-wide simplifications a member-state seller uses without thinking. A Cyprus company sits inside the EU VAT system with a number buyers can check in VIES, zero-rates intra-EU business sales, and uses the one-stop shop for consumer sales across the bloc. Putting the store back inside the single market is the reason to do it; in this corridor the tax saving is not.

Where it goes wrong is the ledger, because a store throws off thousands of small transactions in several currencies whose VAT treatment changes by customer type and destination. Sumly's Shopify and WooCommerce plugins pull orders, refunds, fees and payouts into the books with the correct codes as they happen, so the VAT return is assembled from the trading rather than rebuilt from an export in the last week of the quarter.

Part 3: How the move runs

From the decision to the first invoice out of the Cyprus company: the order, the mistakes people make before you, and two calculations worked through in full.

What does the move look like, month by month?

Circumstances vary, so read this as a shape rather than a schedule.

• Before anything — and we will be blunt about it. We settle with you whether the Georgian company is kept as a subsidiary or wound up, and if the latter, we tell you plainly that the distribution lock sets the pace. Your Georgian adviser confirms your own day count for the transition year under article 34.
• Month one. We incorporate in Cyprus; the ledger opens the same day the order is placed, and we open the Cyprus residency file. If you are winding up, your Georgian adviser registers the commencement and starts the Revenue Service clock.
• Months one to three. We handle the VAT and VIES registration, the social insurance and employee registrations where they apply, and the UBO filing, and we get banking and EU payments moving. You take up the directorship that anchors the 60-day rule.
• Months three to six. You rent or buy the permanent home the 60-day rule requires, and we tell you what qualifies. You move real decision-making to Cyprus and we minute it there — this is the article 29(3) risk being retired, and it is the most important thing on the list.
• Months four to eight. Where the Georgian company is being closed, the audit window runs and the distribution lock expires; your Georgian adviser weighs the auditor's report and the court route if speed matters.
• Month twelve onward. Once you are through a Georgian tax year on the right side of the day count, we request the Cyprus tax residency certificate and register the non-dom status. From there we hold the day counts and the minute book steady for you.

What mistakes do Georgian founders actually make?

The costly ones follow a pattern.

Assuming the Cyprus rate is the point, and being unable to explain to a co-founder why the move made sense. Quoting 15% as the cost of a distribution and discovering the article 97(10) gross-up makes it 17.65%. Registering a Cyprus company and continuing to decide everything from Tbilisi, which article 29(3) treats as management in Georgia whether or not any appointment document exists. Assuming that because Georgia has no CFC rules and no exit tax, the destination has none either — the EU has both. Relying on a small-business or virtual zone status without checking the government ordinance that gates it. Expecting the treaty's 0% rates to apply to a Cyprus entity with no people and no purpose, which is precisely what the principal purpose test refuses. Winding up the Georgian company without noticing that contributed capital comes back untaxed while the surplus does not. And treating the Georgian residence certificate as a formality that can be arranged after the fact.

Two worked examples

A software studio reinvesting everything. Revenue GEL 1,200,000, profit GEL 400,000, all of it going back into hiring and product. In Georgia the profit tax is zero, because nothing is distributed. In Cyprus the company pays 15% on the accrued profit, less whatever the IP Box brings the qualifying share down to. On tax, Georgia wins and keeps winning. The only reason to move is that the studio's next hundred customers are in the EU and the invoices keep stalling on a VAT number that does not appear in VIES.

A consulting group distributing €200,000 and planning an exit. Distributing from a Georgian company costs 17.65% on the grossed-up base plus 5% withholding — about 19.25% all in. Distributing from a Cyprus company to a shareholder who has actually become Cyprus tax resident and non-domiciled costs 15% at the company and GeSY at the shareholder, capped by the €180,000 ceiling. Add the exit: gains on shares are residence-only under both the treaty and Cyprus domestic law. This is the profile where the move pays, and it is also the profile where substance is not optional.

Both examples use headline rates and assume full distribution. Your own reliefs, timing and status change the answer, which is what the meeting is for.

Part 4: Who does the work

You can do all of this yourself. Below is what that costs in time and in money, against what it costs to let us do it.

Do it yourself — or have Sumly do it

There is a real choice here and we will describe both sides of it fairly. On your own, it is the Registrar's forms and fees, a registered office you arrange, VAT and VIES registration, provisional tax twice a year, annual statements, and a ledger that has to satisfy an auditor — while you are also running a move between two tax systems. Through Sumly it is three published prices: formation from €950 one-time, the bookkeeping software from €39 a month, and a Sumly certified bookkeeper at €390 a month, with the books open from day zero and every return prepared box by box.

The software by itself runs the company from Cyprus or from Georgia: invoicing, AI double-entry bookkeeping, live open-banking feeds, every VAT, VIES, provisional and corporate return prepared box by box, live reports, a document inbox with its own email address, mobile receipt capture that books itself, multi-currency invoicing, team roles and the AI assistant — plus payroll at €15 per employee per month, IP Box tracking at €50 a month, Projects at €10 a month, and the e-commerce plugins.

Everything in the catalogue is available to everyone: a virtual address with PO box, with digital scanning of your post into the dashboard wherever you are; nominee director and secretary where a structure genuinely calls for them; the Yellow Slip for EU citizens, which is not the Georgian route; tax residency and non-dom at €750 per person; the registrations bundle covering VAT, social insurance, employees and UBO; audit through Partner Auditors; the store plugins; banking and EU payments; and the expert-lawyer network for complicated relocations.

All of those are extras. Say what you need in the meeting and it comes back as one clear package-deal offer covering the lot — the IP Box application among them where it fits, because it is complex expert work that should be examined with you before anyone attaches a price to it.

Sumly, a law firm, and a traditional bookkeeping firm

Law firm vs Sumly — and what happens when a case gets complicated

Sumly is cheaper and faster, and we work WITH lawyers, not against them. When a case gets too complicated for what Sumly handles directly, we simply connect you with the right expert in exactly the legal field you need help in, and everything gets done according to best practice, always. Either way, it starts the same place: contact us.

The Georgian half of this move belongs to a Georgian adviser and we will always say so. The Cyprus half is a single provider with a single dashboard and four prices you can read before you commit. That is what makes Sumly the best choice for Georgian founders creating a company and relocating to Cyprus.

Why is Sumly the best bookkeeping system for a Cyprus company?

Sumly is the best accounting software for a Cyprus limited company — because it is built for exactly one thing, Cyprus tax law: all 16 Cyprus VAT codes mapped to the official VAT return boxes, VIES and provisional tax native, not a localization. We will defend that sentence anywhere, and the table below is why.

The two Cyprus-built alternatives a Georgian founder will be pointed at are Cybooks and Balabook. We meet their former customers every week, and what they tell us, again and again: workflows that made simple bookkeeping overly complicated, rough edges and glitches, support that left them waiting — a messy experience they were relieved to leave behind.

On every one of these checkable dimensions, Sumly leads. That is a factual comparison — not a matter of taste.

Without hedging: the best support, the best bookkeeping software, the best AI for bookkeeping, the best bookkeeper and the best prices, with everything made straightforward. The detail is published in Sumly vs Cybooks and Sumly vs Balabook, and for the international tools a Georgian founder already knows, Xero, QuickBooks and Sage.

One line on the IP Box bears repeating: the IP Box is the largest single line in a Cyprus product company's tax position — and the easiest one to forfeit through bookkeeping that was never set up for it. That application opens as a conversation rather than as a form, which is one more reason the meeting comes first.

What happens when you get in touch

You do not need to have decided anything before you speak to us, and you do not need your paperwork in order.

1. The meeting. Fifteen minutes. You tell us what you own and when you want to move. We tell you which rules at home catch you, and what the Cyprus side costs.
2. We tell you what kind of case you have. If it is simple, we do all of it — company, books, residency, non-dom — at a fixed price. If it is not, we say so immediately and bring in the specialist it needs.
3. We start. The company is registered, your books open the same day, and you have one point of contact for the whole thing.

Questions Georgian founders actually ask

Frequently asked

Is a Cyprus company cheaper than a Georgian company?

For a founder who reinvests, no — and it is not close. A Georgian company's object of profit taxation under article 97(1) is distributed profit, not earned profit, so accrued, retained and reinvested profit is not taxed at all, for as long as you like. Cyprus taxes profit as it accrues at 15%. If your plan is to keep the money in the business and compound it, Georgia wins outright and this guide is not going to pretend otherwise.

What does it actually cost to take money out of a Georgian company?

More than 15%, because of a gross-up almost every summary misses. Article 97(10) computes the taxable amount by dividing the disbursement by 0.85, so a GEL 100 dividend is taxed on GEL 117.65 and the profit tax is GEL 17.65 — an effective 17.65% on the cash paid out. Add the 5% dividend withholding under article 130(1) and the founder nets GEL 95 from GEL 117.65 of profit, a combined 19.25%.

Does Georgia have an exit tax?

No, and the proof is unusually clean. Article 6 of the Tax Code sets out an exhaustive list of Georgian taxes — five national and one local — and no exit or migration charge appears in it. The structure of the profit tax leaves no room for one either: an unrealised gain inside a Georgian company was never in charge, so there is nothing to accelerate on departure, and article 98¹(2)(a) lets contributed capital come back untaxed.

Are there Georgian CFC rules on a Cyprus company?

There are none. Every occurrence of controlled in the Tax Code is in the transfer-pricing sense — a controlled transaction is a transaction between related persons under article 127(4). A Georgian resident who owns a Cyprus company is not taxed on its undistributed profits, and under article 82(1)(u) would not be taxed on the distributed ones either while remaining Georgian resident.

Will my Cyprus company be treated as a Georgian enterprise if I run it from Tbilisi?

Yes, and Georgia's rule is sharper than most. Article 22(1) makes an enterprise Georgian if its place of business and-or management is in Georgia, and article 29(3) puts the place of management at the place of residence of the managing natural person — expressly including where the enterprise is actually managed by that person with no appointment document at all. The treaty tie-breaker at article 4(3) then reaches the same answer.

What are the Georgia–Cyprus treaty rates?

Zero, zero and zero. Dividends, interest and royalties are each taxable only in the recipient's state under articles 10(1), 11(1) and 12(1) of the 2015 agreement, and the Georgian Ministry of Finance's own treaty table shows the Cyprus row as 0% across all three with a nine-month permanent-establishment threshold. Gains on shares are taxable only where the seller is resident. It is one of the most generous treaties Cyprus has — which is exactly why the MLI principal purpose test matters here.

How do I stop being a Georgian tax resident?

By not being there. Article 34(2) is a pure day count — 183 or more days of actual presence in any continuous twelve-month period ending in the tax year — with no domicile test and no centre-of-vital-interests limb in Georgian domestic law. Article 34(8) resets the status each tax period and says the days that made you resident last year are ignored this year. There is no deregistration filing to complete.

Should I keep or close the Georgian company?

Keeping it is often the cheaper answer. A Georgian subsidiary under a Cyprus parent pays nothing until it distributes, and distributions to the Cyprus parent are 0% under treaty article 10(1) against a 5% domestic rate. Closing it means the Law on Entrepreneurs timetable: a Revenue Service audit window of up to 90 days from registration of the commencement, and a five-month lock before assets may be distributed, reduced to three with an auditor's report and a court decision.

Does Sumly advise on Georgian tax?

No. Sumly builds and runs the Cyprus side: formation, books from day zero, Cyprus VAT, VIES, provisional and corporate returns, and the tax residency and non-dom application. This guide quotes the Tax Code of Georgia and the Law on Entrepreneurs so you can see the shape of the decision, but how article 29 or article 34 applies to your facts is a question for a Georgian adviser. Where a case needs one, we connect you with expert lawyers from our network.

Keep reading

• Every country's route to Cyprus — the departure guide for wherever you are now
• Non-resident company formation — the route that applies outside the EU
• The Cyprus IP Box — how qualifying income reaches an effective 3%
• Cyprus non-dom status — the 17-year exemption in detail
• The Cyprus 60-day rule — day counting and the residency certificate
• How to register a company in Cyprus and what it costs

The calculator on this page uses headline rates, an assumed annual return and full distribution of profit, so it shows the shape of the difference rather than your own outcome — and for a Georgian founder who distributes nothing, the honest figure on the Georgian side is zero. Georgian figures are stated for 2026 in lari; Cyprus figures apply from tax year 2026. All Sumly prices exclude VAT, and government expenses on a formation are invoiced separately once your application is approved.