01 · Facts
A loan to a nonresident founder is treated differently depending on whether the claim is forgiven or remains outstanding upon liquidation.
02 · Assessment in the guide
The guide applies different tax consequences to two specified scenarios, including withholding treatment in the second scenario.
03 · Practical application
Review capital contributions, loan documents and applicable tax regime; the historic guide includes limitations.
Important limitation
This is a historic illustrative tax situation, not individual advice. Verify the status of the source, applicable statutory text and factual assumptions.
შემოსავლების სამსახურის სიტუაციური სახელმძღვანელო (infohub.rs.ge), № 0104
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