Georgia offers a territorial tax system: only income sourced within the country is taxable. To become a tax resident you can either:
- Spend more than six months in Georgia, or
- Qualify as a high‑net‑worth individual with minimal physical presence. This requires:
- Proof of net worth of ₾3 million (≈ US $1.2 million) or income of ₾200 000 (≈ US $85 000) over the previous three years,
- An investment of US $500 000 (bank deposit, real estate, etc.),
- Either a Georgian residency card (obtainable via real‑estate purchase) or proof of US $9 000 annual Georgian‑sourced income (rental, bank interest, or salary from a Georgian company).
Bulgaria
- Flat tax rates: 10 % on personal income, corporate income, capital gains, interest, and royalties.
- Dividends: 5 % tax, but dividends paid to EU/EEA tax‑resident legal entities are exempt.
- Residency: Spend more than six months in Bulgaria and demonstrate that the country is the centre of vital interests.
Romania
- Micro‑enterprise regime (gross revenue < €500 000):
- 3 % tax if no full‑time employees.
- 1 % tax if at least one full‑time employee.
- Dividends: 5 % tax.
- Eligibility: Company’s social capital must not be owned by the state or any public administrative unit.
- Part‑time option: Two or more part‑time employees whose combined hours equal one full‑time employee also satisfy the employee requirement.
Armenia
- Micro‑enterprise threshold: Annual turnover ≤ 24 million AMD (≈ US $50 000).
- Taxation: Exempt from corporate income tax, VAT, and turnover tax.
- Obligations: Must pay import duties and a modest employee tax of 5 000 AMD.
- Eligibility restrictions: Sole proprietors in wholesale, banks, consulting, legal, and similar professional services cannot qualify.
Serbia
- Personal income tax: 10 % plus mandatory health‑care and social contributions.
- Corporate tax & dividends: 15 % each.
- Payroll contributions:
- Employee withholds 30 % of salary.
- Employer contributes 17.9 %.
- CFC rules: None; offshore companies are not taxed based on ownership, though permanent establishment (PE) rules apply.
Montenegro
- Corporate tax, dividends, royalties: 15 % (previously 9 %).
- Inheritance tax: 3 %; gifts are tax‑free.
- Residency: Must spend at least 183 days (full‑time) in Montenegro.
- Tax base: Residents are taxed on worldwide income.
Practical considerations
- Residency thresholds vary from six months to a full year; ensure you meet the physical‑presence requirement for the chosen jurisdiction.
- Investment requirements (e.g., Georgia’s US $500 000) can be satisfied through bank deposits, real‑estate, or company formation.
- Employee‑based tax regimes (Romania, Serbia) may be advantageous if you plan to hire locally.
- Micro‑enterprise exemptions (Romania, Armenia) are limited to specific sectors and turnover caps; verify eligibility before structuring a business.
These countries illustrate a range of low‑tax options across emerging Europe, each with distinct residency, investment, and compliance criteria. Evaluate the specific rates, required presence, and sector restrictions to determine the most suitable jurisdiction for your personal or business tax planning.
