Jurisdiction Note
Georgia — Offshore Crypto Structure (Tbilisi Free Industrial Zone) • 2025
Full country note • Offshore / Free Zone regime • Styled for CryptoWisely
Overview

Tbilisi Free Industrial Zone (FIZ) is Georgia’s most business-friendly, low-tax regime designed to attract international startups, including blockchain and crypto ventures. It operates under a distinct legal and tax framework from mainland Georgia and is typically positioned as an offshore-oriented structure. In practice, many setups are used to serve non-Georgia markets, supported by external banking/PSP arrangements.

Key Highlights
  • 0% corporate income tax (commonly positioned for foreign-sourced activity)
  • No VAT (per FIZ regime structuring)
  • No minimum capital requirement
  • Fast timeline: typically ~2–3 weeks (readiness dependent)
Advantages
  • Tax efficiency for international-facing operations (structure dependent)
  • Lower operational overhead vs fully regulated regimes
  • Legal address model is commonly used (substance expectations may vary by partners)
  • Simple annual renewals (DD refresh + address / admin updates)
Authorized Activities
  • Crypto exchange services (crypto-to-crypto / crypto-to-fiat model depending on counterparties)
  • Custody and wallet services
  • Token offerings (ICO / ITO / IEO) and related project operations
  • Mining / infrastructure operations
  • International payment / remittance processing (typically via external rails)
Licensing Process & Timeline
  1. Company formation (≈ 5–7 days): FIZ LLC setup, KYC for UBO/directors, activity description
  2. License application (≈ 1–2 weeks): authority review of corporate docs, ownership, basic business plan
  3. Approval & activation: license issued and operations can begin (partner onboarding may take longer)
Ongoing Obligations
  • Annual due diligence refresh on UBO/directors
  • Legal address renewal and admin maintenance
  • Renewal fees to keep the license active

Note: Even where local supervision is light, banking/PSP partners often impose their own compliance and substance expectations.

Tax Notes
  • 0% corporate income tax (commonly marketed for foreign-sourced income; structure dependent)
  • 0% VAT for cross-border positioning (confirm specifics for the exact FIZ setup)
  • Dividend tax may apply upon distribution (structure dependent)
Banking & Fiat Rails

FIZ companies often rely on EU/offshore banking or PSP rails for fiat processing. A common pattern is:

  • Georgia FIZ LLC (crypto operations)
  • EU / offshore payment agent entity as fiat gateway (e.g., LT/CY/BG depending on model)
  • Merchant / banking accounts for inbound-outbound fiat flows
Mainland VASP vs FIZ
  • Regulator: Mainland (NBG/FMS) vs FIZ authority
  • Compliance load: Full AML/audit/reporting vs lighter local regime (partners may add requirements)
  • Tax posture: Mainland standard taxation vs FIZ tax incentives
  • Substance: Local director/office vs legal address model (partner dependent)
  • Timeline: ~3–4 months vs ~2–3 weeks
CryptoWisely Support

End-to-end assistance: jurisdiction fit check, structure design (regulated vs offshore), documentation pack, partner onboarding strategy (bank/PSP), website legal/compliance pages, and go-live planning with risk controls.

Disclaimer: This note is for planning purposes only and is not legal or tax advice. Always verify the latest FIZ authority requirements and any banking/PSP partner policies before execution.