Freihandelszonen in Georgien und den VAE: Vergleich der Steuervorteile und -nachteile

Letzte Aktualisierung: Mai 2026

Introduction: Georgia vs. UAE free zones

For international businesses and investors seeking tax-efficient jurisdictions, Georgia and the United Arab Emirates offer two distinct approaches. Georgia’s Free Industrial Zones (FIZ) provide blanket exemptions for goods-based businesses at a fraction of the cost, while the UAE’s 40-plus specialized free zones deliver world-class infrastructure and zero personal income tax — at a higher price point.

Since the UAE introduced its 9% corporate tax in June 2023, the comparison has become more nuanced. Qualifying Free Zone Persons (QFZPs) still pay 0% on qualifying income, but the rules are strict and the penalties for non-compliance are severe. Georgia’s FIZ regime remains simpler, though its benefits are effectively limited to physical goods.

This guide compares both jurisdictions on tax rates, setup costs, banking, substance requirements, and practical business scenarios — drawing on 2026-current data so you can make an informed decision.

Georgia’s tax system and free industrial zones

General tax framework

Georgia operates an Estonian-style distributed profits model: corporate income tax of 15% applies only when profits are distributed as dividends, not when earned. Resident individuals are exempt from tax on foreign-source income, making the country attractive for international entrepreneurs.

Georgia’s four free industrial zones

Georgia has four operational FIZs: Poti Free Industrial Zone (the oldest, established in 2007), Tbilisi Free Zone, Kutaisi Free Industrial Zone, and Hualing Kutaisi Free Industrial Zone. Each provides the same core tax exemptions but differs in location, infrastructure, and industry focus. Poti is strongest for port logistics and warehousing; Kutaisi suits manufacturing; Tbilisi serves companies needing capital-city proximity.

FIZ vs. Virtual Zone vs. Individual Entrepreneur

Georgia offers three distinct low-tax structures. Choosing the right one depends on your business activity.

UAE free zones and the QFZP regime

General UAE tax framework

The UAE introduced a 9% federal corporate tax in June 2023, applying to businesses earning above AED 375,000 annually. However, Qualifying Free Zone Persons (QFZPs) continue to pay 0% on qualifying income — provided they meet strict substance and activity conditions.

Key UAE free zones by industry

The UAE operates over 40 free zones, each specializing in different sectors. Notable zones include DMCC (commodities, digital assets), JAFZA (logistics, physical trade), DIFC (regulated finance), ADGM (financial services), SHAMS and IFZA (low-cost service setups). Choosing the right zone depends on your business activity, budget, and whether you need a specific regulatory framework.

QFZP rules and the 5-year lockout risk

To maintain 0% CIT, a free zone company must qualify as a QFZP each year. Qualifying income includes transactions with other free zone entities, certain foreign-source income, and passive income meeting specific conditions. A de minimis threshold allows non-qualifying income of the lower of 5% of total revenue or AED 5 million.

Pillar Two and the domestic minimum top-up tax

The UAE’s Domestic Minimum Top-up Tax (DMTT) became effective for financial years starting on or after January 1, 2025. It applies to multinational enterprise groups with consolidated global revenue of EUR 750 million or more. Qualifying groups face a minimum effective tax rate of 15% under the OECD Pillar Two framework, regardless of free zone status. For smaller businesses, this has no direct impact — but it signals the UAE’s alignment with global tax transparency standards.

Direct comparison: Georgia FIZ vs. UAE free zones

Vor- und Nachteile Analyse

Georgia FIZ advantages

• Full 0% CIT on all FIZ income for goods-based activities — no qualifying/non-qualifying split
• 0% VAT, 0% dividends, 0% property tax, 0% import/export duties within FIZ
• Substantially lower setup and operating costs than UAE free zones
• Simpler compliance requirements and less administrative burden
• Proximity to European markets through EU trade agreements
• Stable legal framework and improving business environment

Georgia FIZ disadvantages

• 20% personal income tax with no special FIZ rates
• FIZ benefits do not reliably cover services, IT, or consulting (use VZE or IE instead)
• FIZ entities cannot deliver services to Georgian non-FIZ persons
• Only four zones with limited geographic options
• Less developed banking infrastructure compared to UAE
• No direct residency visa path through FIZ registration
• 4% tax on goods traded with mainland Georgia
• Royalties taxed at standard rates (not exempt in FIZ)

UAE free zone advantages

• 0% personal income tax — a major benefit for high-earning employees and founders
• 0% CIT on qualifying income for QFZPs
• 0% withholding tax on dividends, interest, and royalties
• Over 40 specialized free zones with tailored industry regulations
• World-class infrastructure, logistics, and flight connectivity
• 137+ double tax treaties with major economies
• Direct residency visa path through free zone company formation
• Sophisticated international banking system

UAE free zone disadvantages

• 9% tax on all non-qualifying income — distinction can be complex
• 5-year lockout from 0% rate if QFZP conditions are breached
• Strict substance requirements with increasing compliance complexity
• Significantly higher setup costs (AED 35,000–50,000 for DMCC vs USD 2,000–4,000 for Georgian FIZ)
• Higher operating costs including office space, housing, and banking minimums
• DMTT/Pillar Two effective since 2025 for large multinationals (EUR 750M+ revenue)
• Free zone companies cannot operate directly on the UAE mainland without additional licensing
• IFZA and other zones increasingly requiring mandatory financial statements and longer KYC

Practical business scenarios

Scenario 1: International trading company

A company with USD 5 million annual turnover importing and exporting physical goods, primarily dealing with entities outside the host country.

Georgien FIZ: 0% CIT on all trading income, 0% import/export duties, 0% VAT within FIZ. Assuming 15% profit margin (USD 750,000), the company saves USD 112,500 in corporate taxes versus standard Georgian rates. Best for companies targeting Eastern Europe, Central Asia, and needing port logistics (Poti FIZ).

UAE free zone: 0% CIT if all income qualifies as QFZP. If 80% qualifies and 20% is taxed at 9%, the effective rate is 1.8% — about USD 13,500 on the same profit margin. Superior for MENA, Asian, and African markets with access to sophisticated banking and premium warehousing (JAFZA, DMCC).

Scenario 2: IT services company

A software development firm with USD 2 million annual turnover, remote team, and clients worldwide.

Georgia — Virtual Zone Entity (not FIZ): The correct structure for IT services in Georgia is a VZE, not a FIZ entity. The VZE provides 0% CIT on IT services exported outside Georgia, with 5% WHT on dividends. A virtual office is sufficient — no physical zone presence required. The 1% IE regime is another option for freelancers and smaller operations.

UAE free zone: 0% CIT if meeting QFZP conditions, plus 0% personal income tax for employees. For a company with 10 employees averaging USD 60,000 salary, the personal tax savings alone total USD 120,000 per year compared to Georgia’s 20% PIT. Best for companies with highly-paid international staff and MENA-region clients. Tech-focused zones like DMCC and IFZA offer specialized infrastructure.

Scenario 3: Manufacturing business

A consumer electronics manufacturer with USD 10 million turnover, importing raw materials and exporting finished products.

Georgien FIZ: This is the strongest FIZ use case. 0% CIT, 0% VAT, 0% import/export duties, 0% property tax. Assuming 12% profit margin (USD 1.2 million), tax savings of USD 180,000 versus standard rates, plus an estimated 70% lower labor costs than UAE — potentially saving USD 500,000+ annually depending on workforce size. Office and industrial space runs USD 4–7/m² per month in Kutaisi.

UAE free zone: Similar tax savings on qualifying income, but industrial space costs 3–5x more and labor costs are substantially higher. Best for high-margin, high-tech manufacturing needing superior logistics and direct access to MENA, African, or South Asian markets.

Strategic recommendations by business type

Many businesses use hybrid structures: a UAE free zone entity as the global headquarters and trading arm, combined with a Georgian FIZ or VZE entity for manufacturing or back-office operations. This approach leverages the UAE’s connectivity and prestige while keeping costs down through Georgia’s lower operating environment.

If you are also considering Armenia for your international structure, Vardanyan & Partners can advise on how Armenia’s tax and residency frameworks compare. Armenia offers its own Geschäftsanmeldung Vorteile und wettbewerbsfähige Steuersätze, including a 1% IT tax regime for qualifying tech companies.

Häufig gestellte Fragen

Fazit

Georgia FIZ works best for goods-based businesses prioritizing cost efficiency — manufacturing, logistics, and warehousing companies that serve European or Central Asian markets. The tax exemption is straightforward, costs are low, and compliance is manageable.

UAE free zones suit businesses that need global banking infrastructure, 0% personal income tax, or access to MENA and Asian markets — provided they can maintain QFZP compliance and absorb the higher operating costs.

For IT, consulting, and digital services, Georgia’s Virtual Zone or IE regime often offers a better fit than FIZ. And for businesses considering hybrid structures across multiple jurisdictions, professional structuring advice is essential to ensure compliance in each location.

If Armenia is part of your international planning, our team at Vardanyan & Partners can advise on how Armenia’s Steuersystem, Geschäftsanmeldung und Optionen für die Aufenthaltserlaubnis compare to both Georgia and the UAE.