Georgia’s Finance Ministry has published on its website the text of the country’s tax treaty with Kyrgyzstan.
Under the tax treaty, dividends are subject to a withholding tax rate of five percent if the beneficial owner is a company (other than a partnership) which holds directly at least 25 percent of the capital of the company paying the dividends. The withholding tax rate is ten percent of the gross amount of the dividends in all other cases.
Interest and royalty withholding tax rates are set at five and ten percent, respectively.
The tax treaty does not provide for a limitation of benefits clause.
The tax treaty entered into force May 29, 2023.