Paraguay vs Georgia Residency
The clearest contrast on this site between a country that publishes its tax residency test and one that does not.
Last verified 2026-08-20Next review 2026-11-205 official sources
Georgia writes it down. Article 34(2) of the Tax Code makes a natural person a Georgian resident for the entire tax year where they actually stayed in Georgia for 183 or more days in any continuous 12-calendar-month period ending in that year. Article 82(1)(u) exempts income of a resident natural person that is not Georgian-source income. Article 81(1) taxes what is Georgian-source at 20%.
Paraguay publishes no equivalent. No day count for individuals, and territoriality that follows from source rules rather than from a stated exemption for residents. This is the sharpest contrast on this site between a written test and a documentary one.
What Georgia actually says
| Provision | What it establishes |
|---|---|
| Article 34(2) | Resident for the entire current tax year where the person actually stayed in Georgia for 183 or more days in any continuous 12-calendar-month period ending in that tax year |
| Article 34(3) and 34(4) | Time spent abroad for treatment, leisure, business trips or education counts as time in Georgia; time in Georgia for treatment or leisure, and time in diplomatic status, does not |
| Article 34(6) | A separate route for a high net worth individual, under a procedure set by the Ministers of Finance and Justice |
| Article 81(1) | A natural person's taxable income is taxed at 20%, unless the Code provides otherwise |
| Article 82(1)(u) | Income, including gain, received by a resident natural person which does not belong to Georgian-source income is exempt from income tax |
| Articles 88(1) and 90(1) | Small business status for gross income up to GEL 100,000 in a calendar year, taxed at 5% |
Read Articles 34(3) and 34(4) together and something interesting appears: the day count is not a naive tally of nights. A business trip out of Georgia still counts as time in Georgia, while a holiday spent in Georgia does not count towards it. That is unusual, and it is the kind of detail that only exists because someone wrote the test down.
What Paraguay says instead
Ley N° 6380/2019 builds the personal income tax on a definition of source. Income that does not fall within it is outside the charge, subject to the exceptions the law itself lists. There is no article stating that a resident's foreign income is exempt: the result follows from the source rules rather than from an exemption.
And to prove residence, Resolución General N° 65/2020 requires, for individuals, the Constancia de Movimiento Migratorio for the period, alongside a valid cédula and, where the applicant is registered, a RUC in good standing. No day figure appears anywhere in it. We read it in full.
The long version is at is there a 183-day rule in Paraguay.
The trade, stated plainly
Georgia gives you certainty and asks for time
If you can spend 183 days a year in Tbilisi or Batumi, Georgia hands you a statutory test you can point at and a statutory exemption you can cite. In an argument with a foreign tax authority, an article number is a much stronger artefact than a documentary procedure.
Small business status adds something Paraguay has no direct equivalent to: a 5% regime on Georgian-source business income up to GEL 100,000, with clear revocation conditions including VAT registration and breach of the limit.
Paraguay gives you permanence and asks for less
Paraguay's offer is different in kind. Permanent residency and an identity document, at a published fee, with no investment in the general route, in a country cheap enough that living there is not a sacrifice. Georgian residence permits are decided under Georgian immigration law, which is outside the scope of this site and which we are not going to summarise from memory.
Neither is a strategy on its own
Both fail at the same point: leaving the tax residency you already have. Spain applies Article 9 of Ley 35/2006 and can apply the exit tax of Article 95 bis. Argentina requires a filing under RG 4760/2020. Mexico requires an aviso 15 days before the change. Colombia applies Article 10 of the Estatuto Tributario and asks for a foreign certificate. See what Paraguayan residency does not solve.
Information exchange applies to both
Neither country is a hiding place. Paraguay appears among the jurisdictions committed to the OECD's automatic exchange of financial account information standard, and Georgia's position should be checked on the same OECD page rather than assumed. Any plan whose viability depends on nobody looking is not a plan.
Which one for which person
- You can genuinely spend half the year in one place. Georgia, without much hesitation. Take the written test.
- You run a small service business under GEL 100,000. Georgia again: small business status at 5% is a real, published regime.
- You want somewhere to actually settle, with family, on a modest budget. Paraguay. Cost of living and the absence of a capital requirement do most of the work here.
- You are constantly moving. Neither solves you. Georgia's test will not be met and Paraguay offers no alternative test to meet. That profile needs advice, not a country.
- You are leaving a country with an exit tax or a low-tax-jurisdiction rule. Resolve that first. It usually decides the timetable regardless of destination.
What is not established. Georgian immigration law: visa-free stay lengths, residence permit categories and their conditions are set by Georgian immigration rules that we have not read in this pass, so this page publishes none of them. Nothing here should be read as saying that Georgian tax residence and a Georgian residence permit are the same thing. On the Paraguayan side, whether any minimum presence is expected in practice for the tax residency certificate remains open: the Resolución General N° 65/2020 states no day count.
Read next: the full comparison matrix, territorial tax explained and the tax residency certificate.
Common questions
- How does Georgia decide who is a tax resident?
- Article 34(2) of the Tax Code of Georgia makes a natural person a Georgian resident for the entire tax year where they actually stayed in Georgia for 183 or more days in any continuous 12-calendar-month period ending in that year. Article 34(6) provides a separate high-net-worth route under a procedure set by the Ministers of Finance and Justice.
- Is foreign income really untaxed in Georgia?
- Article 82(1)(u) exempts income, including gain, received by a resident natural person which does not belong to Georgian-source income. Georgian-source income of a natural person is taxed at 20% under Article 81(1). That is a statutory exemption you can point at, which is more than Paraguay offers in writing.
- What is Georgian small business status worth?
- Article 88(1) grants it to an entrepreneur natural person whose gross income from economic activity in a calendar year does not exceed GEL 100,000, and Article 90(1) taxes the taxable income of a small business at 5%. It is revoked on breaching the limit or on VAT registration, among other events.
- So why would anyone choose Paraguay over Georgia?
- Because the two answer different questions. Georgia gives you a written day test and a written exemption, and asks you to spend 183 days there to use them. Paraguay gives you permanent residency and an identity document without a published day threshold, in a country most people can also afford to actually inhabit. If certainty on paper is what you need, Georgia is the stronger case and we will say so.
- Can I hold residency in both?
- Holding two immigration statuses is common and creates no conflict by itself. Holding two tax residencies is a different matter, and without a treaty between the countries involved there is no tie-breaker to resolve it. That is the situation to take to an adviser before, not after.
Whether Paraguay works for you depends on how you earn
Not just on where you live. We can walk through your position with you — including the cases where Paraguayan residency does not produce the outcome people expect. This is general information, not tax advice for your circumstances.
Sources
Every legal, fee and procedural statement on this page is taken from the sources below and was checked on 2026-08-20. Where they change, this page changes.
- Tax Code of Georgia — Legislative Herald of Georgia (matsne.gov.ge) — Article 34(2): resident where a person actually stayed 183 or more days in any continuous 12-calendar-month period ending in the tax year. Article 81(1): 20% on a natural person’s taxable income. Article 82(1)(u): income of a resident natural person that is not Georgian-source income is exempt. Articles 88(1) and 90(1): small business status up to GEL 100,000 of gross income, taxed at 5%
- Ley N° 6380/2019 — Biblioteca y Archivo Central del Congreso Nacional — IRP, IRE, IDU and INR: source rules, rates and exemptions
- Resolución General N° 65/2020 — DNIT — Certificado de Residencia Fiscal: requirements, issue time and validity
- Dirección Nacional de Migraciones — Residencias — The residency categories published by the migration authority
- OECD — CRS implementation and assistance — The automatic exchange of financial account information standard and jurisdiction status
Related
This page is general information about Paraguayan rules as published by the authorities named above. It is not legal or tax advice for your circumstances, and immigration outcomes depend on your nationality, documents and individual case. See our legal and tax information disclaimer.