Please be informed that, effective February 25, 2026, the new regulation regarding the reporting of international controlled transactions has come into force.

If the total volume of international controlled transactions carried out by a company during the previous calendar year exceeds GEL 500,000, the company is now legally obliged to submit detailed information regarding these transactions to the Revenue Service. It is important to note that the GEL 500,000 threshold considers not only the actual payments made but also the market value of gratuitous (free-of-charge) transactions, as well as the outstanding balances of accounts receivable and accounts payable.

The reporting requirement applies to all types of international controlled transactions, including but not limited to: the supply/purchase of goods or services, supply/purchase of tangible or intangible assets, receipt/issuance of loans, and interest income/expense.

The required information must include:
The name, identification number, and country of residence of the related party; the nature of the relationship; the type and volume of the international controlled transaction; the outstanding balances of accounts receivable and payable; the date of the contract signature; and information regarding the possession of relevant Transfer Pricing documentation.

Filing and Deadlines:
This information must be submitted annually by completing the corresponding annex within the corporate income tax declaration for the month of March. For entities subject to the annual corporate income tax regime, this information shall be included in their annual tax return. The amendment is already active and applies to the 2025 reporting periods and onwards.

For further information and professional consultation, please do not hesitate to contact us.