Georgia: crypto taxes when leaving Germany

• Territorial principle: Individuals pay tax only on Georgian-source income; foreign income generally stays untaxed, even with full residency. Georgian tax residency is always a prerequisite.
• Disposals: Gains from exchange trading count as non-Georgian income because exchanges have no fixed location. Basis is the Ministry of Finance's public interpretive ruling of 28 June 2019 (crypto assets located in virtual space): 0 % for private individuals. There is no separate statutory threshold.
• Staking, lending, liquidity mining, airdrops, hard forks: According to the prevailing assessment, likewise foreign income at 0 %, provided the activity isn't Georgian business activity. There is no express official confirmation so far; for larger amounts, confirm individually.
• Mining: Mining carried out with hardware in Georgia would likely count as Georgian business activity and be subject to the regular tax rules; check separately beforehand.
• Special regimes: Small-business status for certain activities: 1 % of turnover up to 500,000 lari (around €175,000); unresolved for pure crypto trading, as the central bank could view it as a currency operation. “International Company” (IT): 5 % corporate tax; “Virtual Zone”: 0 %; each with VAT exemption. Ordinary companies: 15 % corporate tax only on distribution, plus 5 % withholding tax on the dividend.
• VAT: Exchanging crypto assets for fiat money and vice versa is exempt.
• Declaration: No official form so far; administrative practice is less developed than in Germany, Austria, or Portugal. Document transactions carefully; Georgian banks demand strict proof of origin for crypto proceeds, and transaction records should be kept for at least five years.
• Wealth and inheritance: No wealth tax, no inheritance or gift tax.

Year of departure

• German unlimited tax liability ends only when residence and habitual abode are actually given up. Georgian tax residency: at least 183 days of presence or HNWI status.
• HNWI route: proven assets of more than 3 million lari or annual income of more than 200,000 lari in each of the previous three years, in each case combined with a connection to Georgia – a residence permit, Georgian real estate worth at least $500,000, or Georgian income of at least 25,000 lari in the previous year, for example. A residency certificate without actual presence only helps if the German residence has actually been given up too.
• If the German home is already given up at the time of sale, the gain is not domestic income under § 49 EStG, regardless of the tie-breaker and the exchange used. Only if both homes still exist in parallel does the tie-breaker apply (permanent home, center of vital interests, habitual abode).
• Anyone wanting to keep substantial economic ties to Germany should, given the potentially very low individual burden from the territorial principle, have the § 2 AStG question calculated through specifically.
• A sale in Germany before emigrating isn't needed: private exchange gains are permanently taxed at 0 % in Georgia.

First year after leaving

• Private exchange trading stays at 0 %, regardless of holding period, trading frequency, or size of gain, as long as the activity isn't Georgian business activity.
• Mining rigs in a rented hall near Kutaisi on Georgian hydroelectric power: the coins would likely be taxed under the regular rules, possibly more favorably via small-business status (1 % of turnover), but not automatically tax-free.

More than ten years

• Unchanged under current law; legislation, case law, and administrative practice can change.
• No separate inheritance tax treaty: for German nationals, German extended unlimited inheritance tax liability applies if the deceased or donor was fully taxable in Germany within the last five years before the inheritance; after more than ten years, the window is closed.

Moving on to a third country

• Georgia has no exit taxation for privately held crypto assets; moving on doesn't trigger any tax there on unrealized crypto gains.

Returning to Germany

• Georgia levies no special tax on the move back. In Germany, unlimited tax liability returns with the re-establishment of a residence or habitual abode; the original acquisition date counts. If a position has been held for longer than a year in total, a later sale in Germany is tax-free under § 23 EStG.