A schedule must be prepared for the tax transfer of assets, assigning assets, debts, provisions, outstanding tax receivables and other tax positions to the relevant entity before and after the reorganisation. For each item, record its previous carrying amount, tax value, transfer date and supporting evidence. Particular attention should be paid to fixed assets, inventory, receivables, contracts, depreciation balances and tax liabilities that have already arisen. Tax succession must not be assumed without verification for losses, credits or tax periods that have not yet closed. The form of reorganisation chosen and the conditions of the applicable tax rules are decisive. The effective date, reorganisation documents, registry records and accounting records must be aligned chronologically so that transactions are assigned to the correct entity. The resulting transfer documentation provides the basis for the required tax filings; submitting them is a separate step.
Tax Treatment of Assets and Liabilities Transferred in a Corporate Reorganisation in Georgia
In a corporate reorganisation in Georgia, the tax treatment of each asset and liability transferred must be determined, including whether it remains with the former entity or the continuing entity. Accounting carrying amounts must not be adopted as tax values without verification.
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The tax transition should be documented item by item because accounting and tax values may differ. Losses, credits and open tax periods also do not automatically transfer to a continuing entity. The form of reorganisation, the effective transfer date and the conditions of the applicable tax rules are decisive.