Disguised Employment and Revenue Service Scrutiny in Georgia (Remote Workers)

The Revenue Service (RS) reviews how remote workers and Individual Entrepreneurs (IEs) describe income and relationships with foreign clients. When contracts, invoices, and actual working patterns look like dependent employment, classification questions can follow—including exposure to standard tax rates and reassessment risk if Small Business Status or similar treatment is challenged.

This note is general information, not advice for your specific file. It explains what auditors tend to compare: commercial deliverables and independence versus subordination, fixed personal schedules, and benefits that mirror employment.

What “disguised employment” means in practice

Independent contractors typically sell defined services or outcomes to clients. Employment, by contrast, usually involves ongoing subordination, integration into the client’s organization, and terms that read like a job (for example, mandatory core hours, paid annual leave as an employee benefit, or exclusive personal service framed as a role rather than a project).

The RS does not use one magic phrase; it looks at the full picture—contracts, payments, email trails, and how you describe activity in registrations and declarations.

Single-client and “one boss” risk

Earning most or all IE revenue from one foreign company is not automatically unlawful, but it raises questions when combined with employment-style clauses. If your only counterparty controls how, when, and where you work as an individual, your file may be tested more harshly than a portfolio of arm’s-length B2B relationships.

How to reduce structural risk (high level)

• Frame agreements around deliverables, milestones, and acceptance, not open-ended “full-time role” language.
• Keep invoicing and scope changes documented as commercial variations.
• Align activity codes and descriptions on RS.ge with what you actually do—vague or aspirational wording is a common weak point.

For a review of your contracts and registration path under current rules, see our Digital Nomad & Remote Work Law service or contact TK Counsel.