25 March 2021
Georgia has published Order No. 45 of 2 March 2021 from the Ministry of Finance, which amends Order No 425 of 18 December 2013 concerning the evaluation of controlled transactions. In particular, Order No. 45 established the procedures for Georgian enterprises to request a unilateral advance pricing agreement (APA). The areas covered by Order No. 45 include:
Order No. 45 is effective from the date of publication (5 March 2021), although a fee schedule must still be issued before applications can be made. This is expected to be issued in the near future.
Note, APA's have been technically allowed under Georgia's transfer pricing rules since December 2013 but have not been granted due to the lack of procedures, now provided by Order No. 45. Further, it was previously provided that future controlled transactions covered by an APA must amount to at least GEL 50 million, but this condition was removed with Order No. 45.
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