Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023

Georgia

Recent developments relating to MAP in Georgia prior to 15 August 2023

Developments relating to MAP in the tax treaty network

• Entry into force of the tax treaty with Kyrgyzstan in May 2023.

Other developments relating to MAP

• Decree on Rule for the Mutual Agreement Procedure defined by the international agreement on the avoidance of double taxation and Rule for the Mutual Agreement Procedure defined by the international agreement on the avoidance of double taxation are in force from July 4, 2023.

Latest Action 14 Peer Review report

• Georgia is yet to be peer reviewed under Action 14.

Tax treaty network of Georgia

• 58 treaties, applicable to 58 jurisdictions (covering all treaties signed, although not necessarily in force)

• status of MLI: in force.

Table 1. State of play of Georgia's tax treaty network

Treaties in line with the Action 14 Minimum Standard following MLI impact	Treaties where actions are ongoing to make them in line with the Action 14 Minimum Standard	Following impact/actions, remaining treaties that are not in line with Action 14 Minimum Standard
38	20	0

Source: OECD

Georgia's MAP programme

Organisation of competent authority function

• 12 persons:

  • four heads of unit

  • six persons working on MAP cases (among which four persons work on other tasks as well):

    • of which, four persons work on attribution/allocation cases and two persons work on other cases.

• contact persons for MAP requests:

  • Ms. Marine Khurtsidze, Head of Tax and Customs Policy Department, Ministry of Finance of Georgia, 16 Gorgasali st. 0105 Tbilisi, Georgia Phone: [phone]; Cell: [phone] | E-mail: [e-mail]

  • Ms. Nini Nebieridze, Head of International Taxation Division, Tax and Customs Policy Department, Ministry of Finance of Georgia, 16 Gorgasali st. 0105 Tbilisi, Georgia Phone: [phone]; Cell: [phone] | E-mail: [e-mail]

  • Ms. Dinara Chubinidze, Head of Legal Department, Revenue Service of Georgia, 16 Gorgasali st. 0105 Tbilisi, Georgia Phone: [phone]; Cell: [phone] | E-mail: [e-mail]

  • Mr. Lasha Koberidze, Deputy Head of Legal Department, Revenue Service of Georgia, 16 Gorgasali st. 0105 Tbilisi, Georgia Phone: [phone]; Cell: [phone] | E-mail: [e-mail].

Figure 1. Competent Authority Organisational Structure

Source: OECD

Table 2. Guidance on the MAP process

MAP guidance	Rule for the Mutual Agreement Procedure defined by the international agreement on the avoidance of double taxation, 4 July 2023	https://www.mof.ge/en/5128
	Order № 258, on the approval of Rule for the Mutual Agreement Procedure defined by the international agreement on the avoidance of double taxation 4 July 2023	https://www.matsne.gov.ge/ka/document/view/5855596?publication=0
MAP profile	1 August 2023	https://www.oecd.org/tax/dispute/Georgia-Dispute-Resolution-Profile.pdf

Overview of Georgia's MAP Statistics for 2022

Georgia did not report any MAP cases in its 2022 MAP Statistics.

Please refer to https://www.oecd.org/tax/dispute/map-statistics-georgia.pdf for details with respect to Georgia's MAP Statistics.