Georgia
A. Progress in the implementation of the minimum standard
Georgia has 56 tax agreements in force as reported in its response to the Peer Review questionnaire. Twenty-three of those agreements, comply with the minimum standard.
Georgia signed the MLI in 2017 and deposited its instrument of ratification on 29 March 2019, listing 34 of its agreements in force at that time. The MLI entered into force for Georgia on 1 July 2019. The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.
Georgia has not listed its agreements with Armenia, Austria, Bahrain, Belarus, Denmark, Egypt, Germany, Japan, Kazakhstan, Malta, Poland, Qatar, Saudi Arabia, Switzerland, Ukraine and the United Arab Emirates. These agreements will therefore not, at this stage, be modified under the MLI. Armenia, Bahrain, Denmark, Egypt, Kazakhstan, Malta, Saudi Arabia, Ukraine and the United Arab Emirates have listed their agreements with Georgia under the MLI.
Georgia has signed a bilateral complying instrument with respect to its agreement Japan.
Georgia indicated in its response to the Peer Review questionnaire that steps have been taken (other than under the MLI) to implement the minimum standard in its agreements with Malta and Poland.1
Georgia is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2
In its response to the Peer Review questionnaire, Germany indicated that its agreement with Georgia did not give rise to material treaty shopping concerns for Germany.
B. Conclusion
Armenia, Bahrain, Denmark, Egypt, Kazakhstan, Malta, Saudi Arabia, Ukraine and the United Arab Emirates have listed their agreements with Georgia under the MLI, which amount to requests to implement the minimum standard.
Georgia has developed a plan for the implementation of the minimum standard in its agreements with Armenia, Austria, Bahrain, Belarus, Denmark, Egypt, Germany, Kazakhstan, Qatar, Saudi Arabia, Switzerland, Ukraine and the United Arab Emirates. Georgia indicated in its response to the Peer Review questionnaire that it intends to expand its list of agreements to be covered under the MLI to include these agreements, and that had intended to provide the revised list of agreements under the MLI before December 2021.
Georgia also indicated that bilateral negotiations would be pursued to implement the minimum standard in its agreements with Azerbaijan*, Iran*, Kuwait*, Moldova*, Turkmenistan* and Uzbekistan*.