Batumi sits close enough to the Turkish border that some Turkish entrepreneurs cross it more often than they cross into central Istanbul. That proximity, a real tax treaty and a light-touch Georgian side are why the flow of Turkish businesses into Georgia is not a projection, it is already happening, concentrated around Batumi and Adjara more than anywhere else in this cluster. None of that answers whether Turkish law considers you to have actually left, and what it keeps doing to you if it does not. Turkish tax residency runs on two independent tests, not a single day count, and getting them wrong is the difference between 1% in Georgia and Turkish income tax on the same money at rates up to 35%.
What a Turkish freelancer running a Georgian IE actually pays
A single Turkish freelancer earning the equivalent of $80,000 a year in self-employment profit, roughly TRY 3,784,000 at the exchange rate this guide was written at, falls into Turkey's progressive income tax bands. Under the 2026 brackets published following Income Tax General Communiqué No. 332, that bill comes to roughly TRY 1,206,900: 15% on the first TRY 190,000, 20% up to TRY 400,000, 27% up to TRY 1,000,000, and 35% on the remainder up to TRY 5,300,000, where our example lands, an average rate close to 32% before social security.
Social security does not stay out of the picture, because Turkey's self-employed pay into Bağ-Kur regardless of how much they actually earn. Bağ-Kur premiums are set as 35.75% for 2026 of a declared income band the self-employed person chooses, not a share of actual turnover, and most people declare at or near the floor. At the 2026 minimum monthly base of TRY 33,030, that floor premium is roughly TRY 141,700 a year.
| Turkey | Georgia (Small Business Status) | |
|---|---|---|
| Turnover / declared profit | TRY 3,784,000 (about $80,000) | $80,000 turnover |
| Income tax (progressive, 15-35% at this level) | ~TRY 1,206,900 | - |
| Georgian tax (1% of turnover) | - | $800 (~TRY 37,840) |
| Bağ-Kur (mandatory, minimum declared band) | ~TRY 141,700/year | None required by Small Business Status itself |
| Total, all-in | ~TRY 1,348,600 (~35.6%) | $800 (1%) |
Add the two lines together and the honest Turkish bill on this income is close to 36%, against Georgia's 1%. Very little of that gap evaporates once you look at what Turkish law does to a departing national, which is the actual subject of the rest of this guide.
Does Georgia's 1% actually apply to you in the first place
Before any Turkish-side analysis matters, the 1% has to genuinely apply to the income, which is a Georgian-side question first. Small Business Status taxes Georgian-source income, and for services that generally means work physically performed in Georgia, or income meeting one of the specific tests in Georgian-source income rules. Registering a Georgian IE while continuing to live and work from Trabzon or Istanbul does not, by itself, make the income Georgian-source. We cover the mechanics fully in Georgia's 1% tax; what follows is what Turkish law does once the income genuinely is Georgian.
What Turkey does when you leave
Turkish full tax liability (tam mükellefiyet) under the Income Tax Law (Gelir Vergisi Kanunu, Law No. 193) rests on two independent tests, and satisfying neither is what actually gets you out. Ikametgah, the domicile concept borrowed from the Turkish Civil Code, exists wherever a person has settled with the intention of residing permanently, closer to Germany's Wohnsitz than a pure address registration. Keeping a family home in Turkey "just in case," even while spending most of the year in Georgia, can keep this test alive regardless of your actual day count. The six-month test looks separately at physical presence of more than six months within a calendar year, and either test alone is enough to keep you a full taxpayer.
This is the detail that trips up more people than anything else in this guide. Georgia's own 183-day test runs on a rolling 12-month window, as covered in Georgia tax residency, while Turkey's six-month test runs on the calendar year, January to December. Someone who spends five months in Georgia at the end of one calendar year and five more at the start of the next has not crossed six months in either Turkish year, even though they spent ten consecutive months outside Turkey. The Sarpi crossing and the wider land border make casual back-and-forth easy, which is exactly what makes both counts easy to lose track of. Track them as two separate clocks, and do not assume one serves the other.
Article 5 carves out narrow exceptions, foreign officials, certain scientists, and people in Turkey purely for treatment, education or a holiday, but these run the opposite direction from what a departing Turkish national needs and rarely apply here. Turkey does not impose a formal exit tax, unlike Germany's exit tax or the deemed-disposition rules some other countries in this cluster run. Turkey also has no multi-year trailing-residence rule of the kind Germany's section 2 AStG or Spain's article 8.2 LIRPF apply: once ikametgah and the six-month test are both genuinely no longer met, Turkish domestic law does not keep reaching for your income for years afterward.
Turkey's CFC regime sits in article 7 of the Corporate Tax Law, built around a foreign kurum, a company, not a sole proprietorship. All three must hold at once: Turkish residents control at least 50% of it, at least 25% of its gross revenue is passive, interest, dividends, royalties, rent or securities gains, and it faces an effective tax rate below 10%. A Georgian IE has no separate legal personality, so there is no kurum for the rule to attach to, and Turkish CFC rules simply do not engage. A Georgian LLC is exactly what the rule is built to reach, but the 25% passive-income test is where most freelance-run structures escape: a consultant, developer or agency invoicing genuine service fees earns active income, not the interest, dividends or rent the test measures.
Turkey and Georgia have had a double taxation agreement in force since 15 February 2010, confirmed on Georgia's Ministry of Finance treaty list, with a standard tie-breaker resolving any dual-residency dispute by permanent home, then centre of vital interests, then habitual abode, then nationality. Bağ-Kur does not stop just because you have moved: liability follows whether your Turkish self-employment registration, esnaf registration, professional chamber membership, or a partnership share, is still open, not where you physically live. Closing it out means actually ending the underlying activity, not simply stopping payment and letting the debt accumulate.
The steps, in order
- End ikametgah in substance, not just on paper. Selling or genuinely giving up any Turkish home is what actually closes this test, not filing a foreign-address declaration alone.
- Track Turkey's six-month calendar-year count and Georgia's rolling 183-day count as two separate clocks, especially if you cross the land border often.
- Register a Georgian Individual Entrepreneur and apply for Small Business Status, either in person or under power of attorney through remote company registration.
- Check whether your Georgian structure's revenue is genuinely active before assuming CFC rules do not apply to an LLC - the 25% passive-income share is what actually decides it.
- Formally close Bağ-Kur by deregistering the esnaf record, resigning a partnership share, or ending chamber membership, rather than letting the debt accumulate.
- Declare your new foreign address to the nearest Turkish consulate within the statutory window, a required step separate from the tax analysis above.
- Keep any continuing Turkish-source income documented and priced at arm's length if it still flows through your Georgian structure.
Timeline and cost
The Georgian side moves fast, and the land border makes it faster still: an Individual Entrepreneur with Small Business Status is typically registered within days in person, or remotely under power of attorney in two to three weeks. The Turkish side takes longer if done properly, genuinely ending ikametgah, tracking both calendars, and formally closing Bağ-Kur, and it is worth budgeting weeks rather than days for that half.
We'll work through your ikametgah position, your actual day count against both Turkey's calendar year and Georgia's rolling 12 months, and whether your Georgian structure genuinely sits outside Turkish CFC rules, before you register anything. Written summary included.
See what it costs
The verdict: a strong fit for a Turkish national
Of the guides in this cluster, Turkey's is one of the cleaner cases, and the real registration numbers around Batumi bear that out. There is no exit tax, no multi-year trailing-residence rule chasing you for a decade, a real treaty with a standard tie-breaker, and CFC rules that most freelance-run structures, IE or LLC, simply sit outside. What remains is manageable: end ikametgah in substance, track the calendar-year count separately from Georgia's rolling one, and close Bağ-Kur properly. Do those three things and this is a strong fit, not a qualified one.
If your situation involves a spouse, co-founder or business partner from a different country, the analysis can look completely different for them even on the same Georgian structure. Our full country-by-country guide compares the treaty position and headline trap across all the countries we cover, including moving from Israel to Georgia. Once you are ready to bank locally, our guide to opening a business bank account in Georgia covers what the branch visit actually involves.
Key takeaways
- Confirm ikametgah has genuinely ended, not just that you have declared a foreign address, before assuming Turkish tax liability has stopped.
- Track the Turkish six-month test against the calendar year separately from Georgia's rolling 12-month count, especially if you cross the land border often.
- Formally close your Bağ-Kur registration rather than letting it run; it is tied to your Turkish registration, not your physical location.
- Check whether your Georgian structure's revenue is genuinely active before assuming CFC rules do not apply to an LLC.
- Keep any continuing Turkish-source income properly documented and priced at arm's length if it flows through your Georgian entity.
- Declare your new foreign address to the Turkish consulate within the statutory window as a separate administrative step.
Frequently asked questions
Does moving to Georgia automatically end my Turkish tax residency?
No. Turkish full tax liability ends only when neither ikametgah nor the six-month presence test in a calendar year is met. Declaring a foreign address to your consulate is a required administrative step, but it is not itself proof that either test has been satisfied.
What is ikametgah and how is it different from the six-month rule?
Ikametgah is a domicile concept from the Turkish Civil Code, the place you have settled with the intention of residing permanently, and it can keep you a Turkish tax resident regardless of your day count if it is not genuinely ended. The six-month rule is a separate, independent test based purely on physical presence of more than six months within a calendar year. Either one on its own is enough to make you a full taxpayer.
Is there a tax treaty between Turkey and Georgia?
Yes. The treaty has been in force since 15 February 2010, confirmed on Georgia's Ministry of Finance treaty list, with a standard tie-breaker article resolving dual-residency disputes by permanent home, then centre of vital interests, then habitual abode, then nationality.
Do Turkish CFC rules reach a Georgian IE?
No. Turkey's CFC regime under article 7 of the Corporate Tax Law is built to reach a foreign company, and a Georgian Individual Entrepreneur has no separate legal personality for the rule to attach to. The income is legally the individual's own from the moment it is earned.
Does the same apply to a Georgian LLC?
Not automatically. A Georgian LLC only counts as a CFC where Turkish residents control at least 50% of it, at least 25% of its gross revenue is passive income, and it faces an effective tax rate under 10%. A services business earning active fees rather than interest, dividends or royalties generally fails the passive-income test regardless of Georgia's low rate.
Does Turkey have an exit tax?
No. Unlike Germany or several other countries in this cluster, Turkey does not treat emigration as a taxable event on unrealised gains. There is no equivalent of a deemed-disposition or exit-tax charge triggered simply by ceasing Turkish tax residency.
How does the land border affect my day count?
It makes routine crossing easy, which is exactly why day-count discipline matters more here than elsewhere. Turkey counts the six-month test on the calendar year, while Georgia counts 183 days on a rolling 12-month window. The two use different clocks, and frequent crossing back and forth can trip one test without you tripping the other, or vice versa.
Do I still owe Bağ-Kur if I move to Georgia?
Yes, for as long as the underlying Turkish registration, your esnaf record, chamber membership, or partnership share, stays open. Bağ-Kur liability follows your Turkish registration status, not your physical location, so it has to be formally closed rather than simply left unpaid.
Does the 1% actually apply if I keep working from inside Turkey?
Generally not. Georgia's 1% only applies to Georgian-source income, which for services usually means work physically performed in Georgia or income meeting a specific statutory test. Registering a Georgian IE while continuing to live and work from Turkey does not, on its own, make that income Georgian-source.