It's written on the HNWI certificate.Do you have a source about the HNWI not being sufficient for DTT purposes?
Moreover, the changes have been discussed at length in this forum about a year ago.
Actually, the HNWI certificate could never be used for international tax purposes since it doesn't qualify for ordinary tax residency.
Well, I don't have the time to go through all of this.HNWI certificate means you are a tax resident in Georgia based on local law.
Now, you can at the same time, get a tax residence certificate from another country. No need to visit the Georgian tax office for this purpose.
For example, if you consider Estonia, solely the existence of a permanent home or, in most practical cases residence permit makes you a tax resident based on local law, so you can also access DTT.
As a result, for avoiding dual residence you can and must get a TRC to certify your non-tax residence in Estonia.
So assuming you have no other ties and sufficient substance in Georgia, Estonia can issue you a tax residence certificate based on the DTT of Georgia-Estonia that according to the treaty, you are a tax resident in Georgia.
Yes, but I assumed being a tax resident elsewhere (in another treaty country), and my CVI outside Georgia (occasional leasure doesn't count for Georgian purposes).
I suggest you check again, then try that yourself in practice and only after that publish your idea. Once you succeeded with your idea, let us all know by submitting/uploading proof of evidence.
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