Georgia Updates Reference to OECD Transfer Pricing Guidelines and Introduces New Rules on Qualification of Controlled Loan Transactions as Capital Contributions

The Georgian Revenue Service has published Order No. 331 of 2 October 2024, which amends Order No. 423 of 18 December 2013 on the evaluation of international controlled transactions. Order No. 331 amends references to the OECD Transfer Pricing Guidelines in Order No. 423 to provide that the OECD Transfer Pricing Guidelines should be referred to in general and the tax authority may refer to the latest edition of the OECD Transfer Pricing Guidelines at the time of a tax audit. Previously, refe…