Orbitax subscribers can now easily follow the latest COVID-19-related tax measures being implemented worldwide. New to Orbitax? Create a free account to access your dashboard and latest tax news.
News Share

The Tax Hub

Daily Tax Newsletter


25 March 2021

Responsive image

Georgia Publishes Order Implementing APA Procedures

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:

  • The procedures for pre-application meetings (meeting request form attached);
  • The APA application requirements, which must be submitted in the Georgian language, with Georgian translations to be submitted for related documentation prepared in another language, if requested by the authority (application form attached);
  • The procedures for processing APA applications, which should be completed within four months with the conclusion of an APA (unless denied), with a possible two-month extension (draft APA template attached); and
  • The annual APA compliance report requirements, which is due by 1 April following each year the APA applies (report template attached).

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.

Powerful Tax Tools


FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.


Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.


Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.


Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.


Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.



Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.


Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.


Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.


Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.


Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.


Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.


Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.


VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.


NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.


Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.


Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

Translate Documents

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More