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Georgia-Liechtenstein

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Update - Tax Treaty between Georgia and Liechtenstein

The income and capital tax treaty between Georgia and Liechtenstein was signed 13 May 2015. The treaty is the first of its kind between the two countries.

Taxes Covered

The treaty covers Georgian profit tax, income tax and property tax. It covers Liechtenstein personal income tax, corporate income tax, capital gains tax, wealth tax, and coupon tax.

Withholding Tax Rates

  • Dividends - 0%
  • Interest - 0%
  • Royalties - 0%

Capital Gains

The following capital gains derived by a resident of one Contracting State may be taxed by the other State:

  • Gains from the alienation of immovable property situated in the other State;
  • Gains from alienation of movable property forming part of the business property of a permanent establishment in the other State; and
  • Gains from the alienation of shares deriving more than 50% of their value directly or indirectly from immovable property situated in the other State

Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.

Double Taxation Relief

Georgia applies the credit method for the elimination of double taxation, while Liechtenstein generally applies the exemption method. However, in the case of income covered by Articles 14 (Income from Employment), 15 (Directors' Fees), and 16 (Artistes and Sportsmen), Liechtenstein applies the credit method.

Entry into Force and Effect

The treaty will enter into force once the ratification instruments are exchanged, and will apply from 1 January of the year following its entry into force.

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