In short
You become tax resident in Georgia by spending at least 183 days there in any continuous twelve-month period. Georgian-source income such as rent then stays taxable. Article 82 of the Tax Code sets out which foreign income is exempt. Whether your home country keeps taxing you is decided by its own law and the double tax treaty. If you keep a home in Germany, you normally remain fully taxable there.
The rules at a glanceThis page describes the law as of November 2026. It is not tax advice and not a plan for emigrating. Have an adviser in both countries look at your case before you move.
Staying or leaving comparedThe rules
The Georgian Tax Code, the German Fiscal Code, the Foreign Tax Act and the 2006 treaty. Each rule tests something different.
Under Article 34 of the Georgian Tax Code, you are resident for the whole tax year if you spent at least 183 days in Georgia in any continuous twelve-month period ending in that year. Any day in the country counts in full. Status is decided afresh each year.
Without the 183 days, people with high net worth can be recognised as resident on application. Under Article 34(6) of the Tax Code, the Minister of Finance sets the procedure. Ask the Revenue Service for the current wealth and income thresholds and further conditions before you apply. The status covers one tax year at a time.
Article 82 of the Tax Code lists the income of resident individuals that is exempt from income tax. Before you move, ask the Revenue Service or a Georgian tax adviser to confirm whether your foreign income falls within it. Rent from a flat in the country is Georgian-source income and stays taxable. Work you do in Georgia can count as Georgian-source income even for a client abroad.
Germany taxes in full anyone with a home there (section 8 of the Fiscal Code) or a habitual abode of more than six months (section 9). If you are resident in both countries, Article 4 of the treaty decides: first a permanent home, then the centre of vital interests, then habitual abode.
German nationals who were fully taxable in at least five of the last ten years, move to a low-tax country and keep substantial economic interests in Germany stay subject to extended limited liability for up to ten years (section 2 AStG). People who were fully taxable in at least seven of the last twelve years and hold at least 1% of a company pay exit tax on unrealised gains when they leave (section 6 AStG). This can also apply if the treaty allocates you to Georgia while you keep a home in Germany.
Comparison
The same 183 days in Georgia have very different results depending on what you keep in Germany.
Simplified for German nationals. Family home, employer and assets can change the outcome.
worldwide income, because a home exists under section 8 AO
German-source income only, such as rent or salary from Germany
A flat you can use at any time is enough to count as a home. Deregistering alone does not end it.
Article 4 looks at the permanent home and vital interests
resident only in Georgia once the 183 days are met
Family, work and assets in Germany often pull the centre of vital interests there, even after 183 days in Georgia.
while you remain fully taxable
section 2 AStG if Georgia counts as low-tax
The Act tests low taxation against a reference income of EUR 77,000 or a preferential regime.
if the treaty allocates you to Georgia and Germany loses its right to tax the shares
section 6 AStG from 1%, payable in seven instalments on request
Exit tax covers shares in companies, not the flat in Georgia. Whether it applies is for a tax adviser to check before you move.
worldwide assets while you live in Germany
German nationals stay fully liable for five years after leaving
There is no inheritance tax treaty between Germany and Georgia.
Residence, health insurance and daily life after a move are covered on the moving page.
Moving to GeorgiaFrequently asked questions
183 days, foreign income, Germany, the Foreign Tax Act and the UK.
By spending at least 183 days in Georgia in a continuous twelve-month period ending in the tax year. Without those days, Article 34 offers only special routes, chiefly recognition of high-net-worth individuals on application. A residence permit on its own does not make you tax resident.
That depends on the exemptions in Article 82 of the Tax Code, so have it confirmed for your own income. Georgian-source income stays taxable, such as rent from a flat in Batumi. Whether work you do while in Georgia counts as foreign-source is a separate question.
Yes, as long as you have a home or habitual abode in Germany. You are then resident in both countries, and Article 4 of the treaty decides which one takes priority. The 183 days in Georgia do not settle that question.
A rule in section 2 of the German Foreign Tax Act for German nationals who move to a low-tax country and keep substantial economic interests in Germany. For up to ten years, more of their income stays taxable in Germany than for other non-residents, provided it exceeds EUR 16,500 a year.
Whether you remain UK resident is decided by the statutory residence test. HMRC explains it in guidance note RDR3, with day counts, ties and work tests. UK tax on a flat in Georgia has its own page.
Last reviewed on November 2, 2026. Sources: Tax Code of Georgia, Art. 34(2), (5), (6) and (8) (residence) and Art. 82 (exempt income) (matsne.gov.ge, version of 15 October 2026), Revenue Service of Georgia (rs.ge): application for a residence certificate, German Fiscal Code, sections 8 and 9; Foreign Tax Act, sections 2 and 6; Inheritance and Gift Tax Act, section 2 (gesetze-im-internet.de), Germany and Georgia double taxation agreement of 1 June 2006, Article 4 (German Federal Ministry of Finance), HMRC, RDR3 Statutory Residence Test (gov.uk). This guide is not legal or tax advice.
Read next
The move itself, German tax for owners and the residence permit.
Tax residence follows your life, not a form. What you keep at home counts as much as your days in Georgia.