Due diligence
Every claim is verifiable. Here is the legal and structural basis for each one.
Aurum does not ask clients to take anything on trust. The following documentation covers the legal basis for all tax claims, the complete entity and custody structure, the banking relationship model, and the evidence base for every yield and treaty figure cited on this site.
T3RRA Ltd (technology) · Georgian SPV per investment · no commingling · MPC custody · CRS-reportable · FATF-clean
Georgian Tax Code Art. 82.2.u · MoF Decision N201 June 2019 · Art. 34.1 HNWI route · 0% IHT by absence of statute · reviewed by international counsel
TBC Bank: TBCG.L · Bank of Georgia: BGEO.L · Basel III · Deloitte + EY audited · SWIFT · no capital controls ever imposed · 30+ years Georgian independence
Georgian LLC/JSC · public land registry · tokenised equity (not derivatives) · L3RS-1 protocol · TBC Capital yield data 2024 · USD 25K minimum per vault
MPC threshold custody (2-of-3) · L3RS Foundation governed · T3RRA certified · NBG ratification pathway · LBMA gold custody Zurich · 11 formal invariants
Complete 58 DTT Treaty Network
| Country | In Force | Dividends | Interest | Royalties |
|---|---|---|---|---|
| Western Europe | ||||
| Austria | 01 Mar 2006 | 10% / 0% | 0% | 0% |
| Belgium | MLI | 5% / 15% | 10% | 5% / 10% |
| Bulgaria | 01 Jul 1999 | 10% | 10% | 10% |
| Croatia | MLI | 5% | 5% | 5% |
| Cyprus | MLI | 0% | 0% | 0% |
| Czech Republic | MLI | 5% / 10% | 8% | 0–10% |
| Denmark | 23 Dec 2008 | 0–10% | 0% | 0% |
| Estonia | 27 Dec 2007 | 0% | 0% | 0% |
| Finland | MLI | 0–10% | 0% | 0% |
| France | MLI | 0–10% | 0% | 0% |
| Germany | 21 Dec 2007 | 0–10% | 0% | 0% |
| Greece | MLI | 8% | 8% | 5% |
| Hungary | MLI | 0% / 5% | 0% | 0% |
| Iceland | MLI | 5% / 10% | 5% | 5% |
| Ireland | MLI | 0–10% | 0% | 0% |
| Italy | 19 Feb 2004 | 5% / 10% | 0% | 0% |
| Latvia | MLI | 0–10% | 5% | 5% |
| Liechtenstein | MLI | 0% | 0% | 0% |
| Lithuania | MLI | 5% / 15% | 10% | 10% |
| Luxembourg | MLI | 0–10% | 0% | 0% |
| Malta | 19 Dec 2009 | 0% | 0% | 0% |
| Netherlands | MLI | 0–15% | 0% | 0% |
| Norway | MLI | 5% / 10% | 0% | 0% |
| Poland | 14 Apr 2023 | 5% | 5% | 5% |
| Portugal | MLI | 5% / 10% | 10% | 5% |
| Romania | 15 May 1999 | 8% | 10% | 5% |
| San Marino | MLI | 0% | 0% | 0% |
| Serbia | MLI | 5% / 10% | 10% | 10% |
| Slovakia | MLI | 0% | 5% | 5% |
| Slovenia | MLI | 5% | 5% | 5% |
| Spain | 01 Jul 2011 | 0% / 10% | 0% | 0% |
| Sweden | 26 Jul 2014 | — | — | — |
| Switzerland | 07 Jul 2011 | 10% / 0% | 0% | 0% |
| United Kingdom | MLI | 0% / 15% | 0% | 0% |
| CIS & Eastern Europe | ||||
| Armenia | 03 Jul 2000 | 5% / 10% | 10% | 5% |
| Azerbaijan | 06 Jun 1998 | 10% | 10% | 10% |
| Belarus | 24 Nov 2015 | 5% / 10% | 5% | 5% |
| Kazakhstan | 05 Jul 2000 | 15% | 10% | 10% |
| Kyrgyzstan | 29 May 2023 | 5% / 10% | 0–5% | 5–10% |
| Moldova | 17 Apr 2018 | 5% | 5% | 5% |
| Turkmenistan | 26 Jan 2000 | 10% | 10% | 10% |
| Ukraine | 01 Apr 1999 | 5% / 10% | 10% | 10% |
| Uzbekistan | 20 Oct 1997 | 5% / 15% | 10% | 10% |
| Middle East & Gulf | ||||
| Bahrain | 01 Aug 2012 | 0% | 0% | 0% |
| Egypt | 20 Dec 2012 | 10% | 10% | 10% |
| Israel | MLI | 0% / 5% | 5% | 0% |
| Kuwait | 14 Apr 2013 | 0% / 5% | 0% | 10% |
| Qatar | 11 Mar 2011 | 0% | 0% | 0% |
| Saudi Arabia | 01 Apr 2019 | 0% / 5% | 0–5% | 5–8% |
| United Arab Emirates | 28 Apr 2011 | 0% | 0% | 0% |
| Asia-Pacific | ||||
| China | 10 Nov 2005 | 0–10% | 10% | 5% |
| Hong Kong | 01 Jul 2021 | 5% | 5% | 5% |
| India | MLI | 10% | 10% | 10% |
| Japan | 23 Jul 2021 | 5% / 10% | 5% | 0% |
| Singapore | MLI | 0% | 0% | 0% |
| South Korea | MLI | 5% / 10% | 0–10% | 5–10% |
| Near East | ||||
| Iran | 14 Feb 2001 | 5% / 10% | 10% | 5% |
| Turkey | 15 Feb 2010 | 10% | 10% | 10% |
MLI = treaty updated under the OECD Multilateral Instrument (ratified by Georgia, December 2018). Source: Georgian Ministry of Finance · mof.ge/en/doubleTaxation · Verified March 2026.
Note: No double tax treaty exists between Georgia and the United States, Canada, or Australia. Residents of these jurisdictions should obtain independent cross-border tax advice.
TBC Capital 2024 · Knight Frank Q4 2024 · MoF DTT register March 2026 · MONEYVAL Feb 2024 · EU-Georgia AA July 2016 · World Bank EoDB
BoE CBDC Sandbox 2020 · AgriDex 2020 · Fiat-on-Chain 2022 · Cleverjet 2024 · NBG under evaluation
CRS-compliant · automatic exchange of information · annual audited SPV accounts · secondary market exit · no Georgian exit tax · 24-month recommended minimum
This section constitutes the evidence and legal basis for all material claims made on this site. It does not constitute legal or tax advice. Clients are strongly encouraged to seek independent advice from qualified legal and tax counsel in their home jurisdiction before making any investment or relocation decision. Aurum engages international legal counsel alongside local Georgian tax counsel. Individual legal and tax positions vary.
Common questions
The questions every serious client asks. Answered directly.
Political risk
"Georgia's political situation concerns me."
This is the right question to ask and we raise it ourselves. The current Georgian government has distanced itself from EU accession talks — a political decision with real geopolitical consequences. What it has not done, and what no Georgian government has ever done, is touch the tax code, impose capital controls, or interfere with the banking system. TBC Bank (TBCG.L) and Bank of Georgia (BGEO.L) have operated through every Georgian political crisis since 1991 and remained fully functional, LSE-listed, and Basel III compliant throughout. The territorial tax system is codified law, not a concession — it does not require political goodwill to maintain.
Mitigation: LSE-listed banks · SPV isolation · tax law independent of government policy · no capital controls ever imposed
Banking resilience
"What happens to my money if the system comes under stress?"
TBC Bank and Bank of Georgia are internationally listed, Basel III regulated, with full SWIFT correspondent relationships through major European clearing banks. Both hold capital ratios above Basel III minimums and are audited by Big Four firms. Georgia has never imposed capital controls in its 30+ year history — including through the 2008 war, the 2014 Russian sanctions crisis, and the COVID shock. Client assets within Aurum vaults are held in SPV-isolated structures, not on bank balance sheets.
TBC Bank: TBCG.L · Bank of Georgia: BGEO.L · Basel III · Big Four audited · zero capital control history
Exit clarity
"What if I need to leave or restructure in the future?"
Georgia imposes no exit tax. Selling Georgian assets, closing a Georgian bank account, or ending Georgian tax residency is straightforward and involves no punitive exit event. Vault positions can be sold on the secondary market. Georgian tax residency simply lapses if the 183-day rule is not met — there is no formal exit process required. There is no lock-in.
No exit tax · no capital controls · vault liquidity via secondary market · residency lapses naturally
Home country compliance
"Will this create problems with my home country tax authority?"
Georgia has 58 double tax treaties covering every major jurisdiction including the UK, Germany, France, UAE, and the full CIS. Aurum structures every client arrangement to be fully reportable and fully compliant with home-country disclosure obligations under CRS. We engage international legal counsel alongside local tax counsel. This is onshore, transparent, and treaty-backed — the opposite of an offshore structure that relies on opacity.
58 DTTs · CRS-compliant · full documentation · reviewed by international counsel
Legacy and succession
"How does this work across generations?"
Consider a client with a USD 20M estate. In the UK, that estate faces 40% IHT above the £325,000 nil-rate band — approaching USD 8M in tax. In Georgia, the same estate passes to the next generation with zero inheritance tax, zero gift tax, and zero wealth tax. Over two generations, the compounding of that saving — reinvested at 7–12% commercial yields — is transformational.
0% IHT · 0% gift tax · USD 8M saving on USD 20M estate vs UK · family residency structuring available
Zero days required
"How many days do I need to spend in Georgia to qualify for HNWI tax residency?"
Zero. The HNWI programme under Ministry of Finance Decree #60 has no minimum physical presence requirement. Standard Georgian tax residency requires 183 days in any 12-month period. The HNWI route is different: it is a purely financial qualification. You do not need to visit, stay in, or be physically present in Georgia at any point during the year to obtain or maintain HNWI tax residency status. Qualification is based entirely on your asset position and economic connection to the country.
MoF Decree #60 (2023) · Zero days required · Purely financial qualification · USD 500K Georgian assets + global wealth criteria
Source-country tax
"Does Georgian HNWI tax residency mean I stop paying tax in my home country?"
Not automatically — and this distinction matters. Georgian HNWI residency establishes Georgia as your country of tax residence and means Georgia taxes your foreign-source income at 0%. What it does not do is prevent other countries from taxing income that originates within their borders. A company in Germany paying you dividends will still withhold German tax before the money reaches you. Rental income from a UK property is still taxable in the UK. That is source-country taxation, and it applies regardless of where you are tax resident. More significantly: other countries have their own rules for establishing tax residency. If you maintain a permanent home in France, spend substantial time in Italy, or keep your family and business centred in any other jurisdiction, that country may assert its own residency claim over you — and your Georgian certificate will not automatically override it. Double tax treaties between Georgia and those countries contain tie-breaker rules to resolve conflicts, but the tie-breaker follows genuine life connections, not paperwork. Georgian HNWI residency is most powerful for individuals who are genuinely internationally mobile, have already reduced or severed tax residency ties to a previous high-tax jurisdiction, need a recognised tax residency certificate from a stable jurisdiction, and structure their financial life across multiple countries without crossing residency thresholds in any one of them. Every situation is different. Aurum's advisors will assess your specific position before recommending any course of action.
Source-country withholding still applies · DTT tie-breaker rules based on genuine connections · best suited for genuinely mobile individuals
Dual residency claims
"What happens if both Georgia and another country claim me as a tax resident?"
If two countries both assert tax residency over you under their respective domestic laws, the Double Tax Treaty (DTT) between those countries determines which one prevails. Georgia has DTTs with 58 countries. The tie-breaker provisions in these treaties typically look at, in order: where you have a permanent home; where your personal and economic relations are closer (centre of vital interests); where you habitually reside; and citizenship. If your genuine life — your home, family, business activity — is centred in another country, the tie-breaker will likely favour that country, not Georgia, even if you hold a Georgian HNWI certificate. This is why the Georgian HNWI programme works for people who are genuinely internationally mobile, not as a paper overlay on an otherwise unchanged life. For countries without a Georgian DTT — including the United States for US citizens, who are taxed on worldwide income regardless of where they reside — the analysis is more complex and requires specific advice.
58 DTTs with tie-breaker provisions · centre of vital interests test · US citizens taxed on worldwide income regardless of residency
Time commitment
"I cannot commit to living in Georgia full-time."
You do not need to — in fact, you do not need to commit to any time in Georgia at all. The HNWI tax residency route has no physical presence requirement under Ministry of Finance Decree #60. A USD 500,000 investment in qualifying Georgian assets plus proof of GEL 3 million in global wealth (or 3 years of GEL 200,000+ income) establishes HNWI status. You can continue to live in London, Dubai, Singapore, or anywhere else and retain Georgian tax residency as your primary legal tax position without ever setting foot in the country.
HNWI route: Zero days required · USD 500K Georgian asset · GEL 3M global wealth · live anywhere
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