Moving from Italy to Georgia for the tax rate is the easy part to research. Registering an Individual Entrepreneur and getting Small Business Status takes days, and the 1% is real. What decides whether it actually holds up for an Italian national is a narrower question than most guides admit exists: is Georgia on the list that reverses your burden of proof under article 2(2-bis) TUIR? We checked it directly against the decree that defines the list, and the answer is no - which changes the shape of everything that follows.
What EUR 80,000 of freelance income actually costs, here and there
Start with the number, because it is the reason anyone reads this far.
Take an Italian freelance professional turning over EUR 80,000 a year, under the EUR 85,000 revenue cap for the regime forfettario, Italy's flat-rate regime for small self-employed activities. For a professional or technical activity, the coefficiente di redditività is 78%, so taxable income works out to EUR 62,400. INPS Gestione Separata, the social security fund for professionals without their own dedicated cassa, charges 26.07% on that imponibile for 2026, confirmed by INPS's own 2026 circular - roughly EUR 16,268, deductible before the flat substitute tax applies. That leaves a base of about EUR 46,132, taxed at the ordinary imposta sostitutiva rate of 15% (5% for the first five years of a genuinely new activity), adding roughly EUR 6,920.
| Italy (regime forfettario, 2026) | Georgia (IE + Small Business Status) | |
|---|---|---|
| Turnover | EUR 80,000 | EUR 80,000 |
| Taxable base (78% coefficient) | EUR 62,400 | Not applicable - taxed on turnover |
| INPS Gestione Separata | ~EUR 16,268 | None required by the status itself |
| Imposta sostitutiva (15%) | ~EUR 6,920 | 1% of turnover |
| Total, all-in | ~EUR 23,188 (~29%) | ~EUR 800 (~1%) |
Most of that bill is the INPS contribution, not the tax itself - the real saving from moving is mostly a social-contributions saving, similar to what French and Spanish movers see.
Does Georgia's 1% actually apply to you
The 1% only applies to Georgian-source income, and for services that generally means work physically performed inside Georgia, not work billed through a Georgian registration while you sit in Milan or Rome. We cover this fully in Georgia's 1% tax and 1% tax without living in Georgia. An Italian national who registers a Georgian IE and keeps working from an apartment in Turin has a source-of-income problem before Italian tax law even enters the picture, because the work never actually left Italy.
What Italy does when you leave
Every Italian citizen relocating abroad for more than twelve months must register with AIRE through the consulate covering the new address within 90 days of the move. AIRE removes you from the ordinary municipal population register, but it is a civil act, not the substantive tax residency test - it is the first item on the checklist, not the last.
Article 2 TUIR, rewritten by Legislative Decree 209/2023 from 1 January 2024, makes an individual Italian tax resident for the greater part of the year if they satisfy at least one of four alternative tests: population registry, domicile, habitual residence, or mere physical presence, confirmed on Fiscoetasse's coverage of the 2024 reform. Domicile is now defined narrowly as personal and family relationships, somewhat easier to break by relocating a family life. But physical presence now counts on its own, including part days, and the reform explicitly extends this to remote workers: someone who spends the majority of the year physically in Italy while working for a Georgian registration is resident under presence alone, regardless of AIRE status.
This is the single most important fact in this guide. Article 2(2-bis) TUIR provides that an Italian citizen removed from the population registry who moves to a State identified by the Decreto Ministeriale of 4 May 1999 is presumed, unless proven otherwise, to remain Italian tax resident - the burden of proof reverses onto the taxpayer. We checked that decree directly against Fiscomania's full enumeration of the current list, roughly fifty jurisdictions including Andorra, the UAE, Hong Kong, Monaco, Panama, Singapore and a long Caribbean and Pacific tail. Georgia does not appear on it, under any name. Article 2(2-bis)'s reversed burden of proof therefore does not apply to a move here - the ordinary article 2 TUIR test still has to be satisfied on the facts, but the presumption never engages, and if the Agenzia delle Entrate wants to argue you never really left, it carries the burden of showing that, not you.
Article 166 TUIR imposes exit taxation on taxpayers carrying on a commercial business who transfer their residence abroad, taxed on unrealised gains against the business's assets. This targets an actual azienda with assets, stock or goodwill, not self-employed professionals earning lavoro autonomo income under article 53 TUIR - a typical mover on the regime forfettario generally has nothing for this to tax.
Article 167 TUIR, Italy's CFC regime, applies to individuals as well as companies, confirmed on Brocardi's TUIR reference - unlike Germany, France or the Netherlands, there is no blanket exemption for direct personal ownership. But the rule requires a foreign "impresa, società o ente" with separate legal personality. A Georgian IE has none, so there is no entity for the rule to attribute income from, putting it outside article 167's scope structurally. A Georgian LLC is different: CFC transparency engages only where the entity is taxed below 15% and more than a third of its revenue is passive. Georgia's 0% rate on retained LLC profit clears the first test easily, but an LLC earning ordinary active service income to unrelated clients generally will not clear the second. Where it does apply, Italian law offers a simplified 15% substitute tax on accounting net profit instead of the full look-through calculation, running for three years and renewing automatically unless revoked.
Italy and Georgia have a working double taxation convention, signed in Rome on 31 October 2000 and in force from 19 February 2004, confirmed on Fiscomania's list of Italy's double taxation treaties, with the standard tie-breaker of permanent home, centre of vital interests, habitual abode and nationality. It does not settle whether Italian residency is genuinely broken, though the article 2(2-bis) analysis already comes out clean for Georgia specifically.
If you were on the regime forfettario, note the cliff: revenue between EUR 85,000 and EUR 100,000 keeps you in the regime for that year but excludes you from the next, while crossing EUR 100,000 mid-year triggers immediate exit with VAT applying from the invoice that crosses it, confirmed on Fiscomania's coverage of exceeding the forfettario limits. Italian-source income kept after leaving - rental property, Italian clients - remains taxable in Italy as a non-resident regardless of the move.
The steps, in order
- Register with AIRE through the consulate within 90 days of moving - required, but only the first step, not proof residency has ended.
- Confirm the post-2024 article 2 TUIR position on the facts: domicile, habitual residence and physical presence all count, and spending most of the year in Italy defeats the move even while working for a Georgian registration.
- Check any existing business assets against article 166 before you leave, if you run a registered Italian business with real azienda assets rather than lavoro autonomo income.
- Register a Georgian Individual Entrepreneur and apply for Small Business Status, either in person or under power of attorney through remote company registration.
- Choose an IE over an LLC if article 167 CFC exposure is a live concern, since an IE sits outside it structurally while an LLC only escapes if its income is genuinely active.
- Close out the regime forfettario or ordinary partita IVA correctly before the year ends, watching the EUR 85,000-100,000 cliff if you are still trading.
- Confirm your Georgian tax residency position separately from the registration itself, since holding Small Business Status does not by itself make you tax resident here.
Timeline and cost
The Georgian side is fast: an IE with Small Business Status is typically registered within days in person, or a few weeks under power of attorney. The Italian side takes longer to close out properly - AIRE registration, confirming the article 2 TUIR position against your actual facts, and, if you already run a business with real assets, a proper look at article 166 before you decide anything. Budget for an Italian commercialista to handle the departure-year filing.
The verdict for an Italian national
Georgia is a strong fit for an Italian national who genuinely relocates. The blacklist question, the one fact that could have flipped this entire guide, comes out clean: Georgia is not on the DM 4 maggio 1999 list, so article 2(2-bis) TUIR's reversed burden of proof never engages. A real treaty has been in force since 2004, article 166 rarely touches a plain self-employed mover, and even article 167's CFC rules - broader than most of this cluster since they do reach individuals directly - leave a Georgian IE outside their scope entirely and an LLC out of scope too, provided its income is genuinely active. What remains are the ordinary conditions: satisfy the post-2024 article 2 TUIR test rather than assuming AIRE alone is enough, register the AIRE change within the 90-day window, and pick an IE or an LLC based on how the underlying income is actually earned.
We'll work through whether your Italian residency is genuinely breakable given your specific ties, what article 167 TUIR means for an IE versus an LLC in your case, and what the honest all-in comparison looks like once INPS contributions are counted properly.
See what it costs
For the same analysis built for a different departure point, see our guides on moving from the Netherlands to Georgia and moving from Spain to Georgia, and for the Georgian residency side of this, see Georgia tax residency. A free consultation is the fastest way to get a straight answer on where your own situation actually sits.
Key takeaways
- Register with AIRE within 90 days of moving, but treat it as step one, not proof residency has ended.
- Confirm the post-2024 article 2 TUIR test on the actual facts - domicile, habitual residence and physical presence all count.
- If you already run an Italian business with real assets, check article 166 exit taxation before you decide anything.
- Pick an IE if article 167 CFC exposure is a concern; an LLC only clears it if its income is genuinely active rather than passive.
- Watch the regime forfettario's EUR 85,000-100,000 cliff if you are still trading through the departure year.
- Register the Georgian IE and Small Business Status only once the Italian side above is genuinely resolved.
Frequently asked questions
Is Georgia on Italy's blacklist?
No. We checked the Decreto Ministeriale of 4 May 1999, the decree article 2(2-bis) TUIR points to, and Georgia does not appear on it. This means the reversed burden of proof that applies to Italians moving to blacklisted jurisdictions does not apply to a genuine move to Georgia.
Is AIRE registration enough to end my Italian tax residency?
No. AIRE removes you from the resident population registry and is required within 90 days of moving, but Italian tax residency under article 2 TUIR is a separate, substantive test based on registration, domicile, habitual residence or physical presence. AIRE alone does not settle it.
What changed in Italian tax residency rules in 2024?
Legislative Decree 209/2023 rewrote article 2 TUIR from 1 January 2024. Domicile is now defined narrowly as personal and family relationships rather than including business interests, but a new standalone physical-presence test means spending the majority of the year in Italy - even while working remotely for a foreign registration - is enough on its own to remain resident.
Does the Italian exit tax under article 166 TUIR apply to a Georgian IE?
Rarely. Article 166 targets people carrying on a commercial business with real assets, not self-employed professionals earning lavoro autonomo income, which is how most freelancers are classified. A typical mover with no substantial business assets generally has nothing for this provision to tax.
Do Italian CFC rules reach a Georgian Individual Entrepreneur?
No. Article 167 TUIR requires the foreign holding to be a separate legal entity. A Georgian IE has no separate legal personality, so there is no foreign entity for the rule to attribute income from.
Does the same apply to a Georgian LLC?
Not automatically. A Georgian LLC is a separate legal entity and can be caught if it is effectively taxed below 15% and more than a third of its revenue is passive - dividends, interest or royalties. An LLC earning genuine active service income to unrelated clients generally falls outside the test.
What happens if my Italian business grows past the regime forfettario limits before I leave?
Revenue between EUR 85,000 and EUR 100,000 in a year keeps you in the regime for that year but excludes you from the next. Crossing EUR 100,000 mid-year ends the regime immediately, and VAT starts applying from the invoice that crosses the threshold.
Can I keep Italian clients after I move to Georgia?
Yes, but income that remains Italian-source may still be taxable in Italy as a non-resident regardless of where you live, and if you keep working from Italy for significant stretches of the year, the post-2024 physical-presence test can make you Italian tax resident again on that basis alone.