Rental income (Article 6)
Income from immovable property may be taxed in the country where the property is located. Georgia may therefore tax the rent from your apartment there.
- Taxed in
- Georgia
- Austria
- exemption
Austrian tax. Georgia taxes the rent, Austria counts it for the rate.
In short
If you are resident in Austria and let an apartment in Georgia, the 2005 double tax treaty gives Georgia the right to tax the rent. Austria exempts the rental income and any gain on sale (Article 23(1)), but may take the rental income into account when setting the rate on your other income. You still have to declare the income. Austria has levied no inheritance or gift tax since August 2008.
What the treaty saysThis page gives an overview and does not replace tax advice. Tax in Georgia itself has its own page.
Rental tax and property tax in GeorgiaThe treaty
What the Austria-Georgia treaty provides.
Treaty of 11 April 2005 (Federal Law Gazette III no. 60/2006). A protocol and additional protocol (Federal Law Gazette III no. 83/2018), in force since 1 March 2013, change the rules on dividends and exchange of information, not those on rent and sale.
Sale (Article 13)
Georgia may also tax gains on selling the apartment, and Austria exempts them under Article 23. Austria's 30% special rate on property gains under section 30a of the Income Tax Act (ImmoESt) therefore does not, as a rule, apply to this apartment.
- Taxed in
- Georgia
- ImmoESt
- not as a rule
Method (Article 23(1))
Austria avoids double taxation by exemption. Only for dividends does it credit the Georgian tax. Exempt income may be included when setting the tax on the rest of your income.
- Method
- exemption with progression
- Credit
- dividends only
Multilateral Instrument
Whether the OECD Multilateral Instrument changes the treaty is shown in the synthesised text. The Ministry of Finance prepares one once the instrument enters into force for a treaty and adds it to its treaty list. Check the version for your tax year there with your tax adviser.
- Where
- the BMF treaty list
- Check
- the version for your tax year
Inheritance and gifts
Austria has levied no inheritance or gift tax since 1 August 2008. Gifts of cash, receivables or company shares, for example towards the purchase, must however be reported to the tax office within three months once certain value limits are exceeded (section 121a BAO). Real estate is not covered by this duty. What applies in Georgia on inheritance is on the inheritance page.
- Inheritance tax
- none since August 2008
- Gifts
- report under section 121a BAO
In your return
What you do in Austria.
The basics for people fully liable to Austrian tax. A tax adviser can confirm how they apply to you.
Compute the income under Austrian rules
For the progression clause, what counts is not the Georgian gross rent but the net income under Austrian law: rent less deductible costs such as depreciation, interest and management.
File on forms E1 and E1b
The income goes in the E1 income tax return. Annex E1b is used to compute income from letting. The Ministry of Finance's filling-in guide for each year shows which boxes apply to foreign income.
Losses
A loss on the apartment in Georgia falls under the rules for foreign income in section 2(8) of the Income Tax Act. Its effect depends on the individual case.
Paperwork from Georgia
Keep the sale contract, registry extract, rental statements and Georgian tax assessments, translated where needed. The tax office may ask for them.
Reporting to the OeNB
The Austrian central bank (OeNB) surveys acquisitions and disposals of foreign property by residents worth EUR 100,000 or more, including by inheritance or gift (the AWVLM survey). The report is due by the 15th of the following month. It is for statistics and is not a tax.
Frequently asked questions
Questions about Austrian tax.
Rental income, real estate gains tax, progression, inheritance and the difference from Germany.
Do Austrian residents pay tax on rental income from Georgia?
Not directly. Under the treaty Georgia taxes the rent and Austria exempts it. The income does raise the rate on your other income, though, so it belongs in your return.
Is Austrian real estate gains tax due when I sell an apartment in Georgia?
As a rule not for an apartment in Georgia, because Austria exempts the gain under Article 23 of the treaty. Georgia may tax the gain; after more than two years of ownership it is tax-free there.
What is the progression clause?
Exempt foreign income is not taxed itself but is included when working out your tax rate. If you have Georgian rental income alongside a salary, the salary is taxed at a higher average rate.
Is there Austrian inheritance tax on the apartment?
No. Austria has levied no inheritance or gift tax since 1 August 2008. Georgian rules and the reporting duty for certain gifts still need checking.
Do the same rules apply as for German residents?
Similar in outcome, different in detail. Both treaties exempt rental income subject to progression. Austria has its own rules on property gains, losses, gifts and forms.
Last reviewed on 2 November 2026. Sources: Austria-Georgia double tax treaty of 11 April 2005, Federal Law Gazette III no. 60/2006, Articles 6, 13 and 23 (ris.bka.gv.at), Protocol and additional protocol amending the treaty, Federal Law Gazette III no. 83/2018, in force since 1 March 2013 (ris.bka.gv.at), Explanatory notes to the government bill, 892 der Beilagen XXII. GP (parlament.gv.at): exemption with progression, credit for dividends only, Austrian Ministry of Finance (bmf.gv.at): Multilateral Instrument; treaty list with synthesised texts, Austrian Income Tax Act 1988, sections 2(8) and 30a; Federal Fiscal Code, section 121a; Ministry of Finance: reporting gifts, Austrian Ministry of Finance (bmf.gv.at): forms E1 and E1b with filling-in guides, Oesterreichische Nationalbank (oenb.at): AWVLM report on cross-border capital transfers and real estate. This guide is not legal or tax advice.
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