Recent amendments to the Georgian Tax Code (GTC) introduce important updates to the way tax enforcement actions are managed. Effective from April 2025, new rules will impact the suspension of the tax limitation period, extending the circumstances under which tax authorities can pursue outstanding liabilities. These changes mark a significant development for taxpayers, particularly those engaged in disputes or settlement negotiations.
Key Amendments to the Georgian Tax Code
Until now, the limitation period for the collection of tax debts was generally three years, starting from the end of the calendar year in which the debt arose, unless otherwise provided by law.
The newly introduced amendments to Article 4, Part 10 of the GTC provide that enforcement measures can now be suspended during the following periods:
- Tax dispute resolution processes (existing rule),
- The validity of an agreement for deferred tax payments (new rule),
- The validity of a Tax Agreement Act (new rule),
- Where an enforcement action is cancelled by decision of the Minister of Finance or the Head of the Revenue Service (new rule).
Furthermore, changes to Article 4, Part 11 of the GTC stipulate that the limitation period will not apply not only when executing court or dispute resolution body decisions, but also when the Tax Authorities submit a petition to declare a taxpayer fraudulent under Article 246.
Eurofast's Take
The updated legislation strengthens the authorities' ability to secure tax debts, especially in cases involving complex disputes or fraudulent activities. While these measures enhance tax compliance, they also place an additional compliance burden on taxpayers, who may face extended liability periods.
At Eurofast, we assist clients in understanding the full impact of these changes, ensuring strategic preparation for tax audits, disputes, and settlement discussions. Our experienced team in Tbilisi is ready to guide you through every stage of the process.
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