Georgia — Corporate Income / Franchise Tax

Georgia imposes a corporate income tax on every domestic corporation and every foreign corporation that owns property in Georgia, does business in the state, or receives income from Georgia sources. The tax is imposed on the corporation's Georgia taxable net income at a rate of 5.19 percent. Georgia taxable net income starts with the corporation's federal taxable income and applies Georgia-specific adjustments. If an S corporation election is recognized for Georgia purposes, the shareholders pay the tax rather than the corporation itself.

Source: Corporate Income and Net Worth Tax, Georgia Department of Revenue

Georgia corporate income tax returns are due by the 15th day of the fourth month following the close of the tax year. For calendar-year C corporations, this means April 15. S corporation returns (Form 600-S) are due by the 15th day of the third month following the close of the tax year—March 15 for calendar-year filers. Corporations may request a six-month filing extension by filing Form IT-303 or by obtaining a federal extension via IRS Form 7004; however, an extension to file does not extend the time to pay any tax liability, which remains due on the original due date.

Source: Tax Due Dates, Georgia Department of Revenue

Georgia imposes corporate income tax at 5.19 percent of a corporation's Georgia taxable net income for taxable years beginning on or after January 1, 2025. This flat rate applies to C corporations. S corporations that make an entity-level election under Georgia law are taxed at the same rate; otherwise, shareholders pay individual income tax on their distributive shares.

Rate reduction from 5.39% to 5.19%. House Bill 111, enacted in 2025, reduced Georgia's corporate income tax rate from 5.39 percent to 5.19 percent. The legislation amended O.C.G.A. § 48-7-20, which governs individual income tax rates, to lower the rate effective for taxable years beginning on or after January 1, 2025. The act itself became effective July 1, 2025.

Scheduled further reductions to 4.99%. Under HB 111, the corporate income tax rate is scheduled to decrease by 0.10 percentage points annually—reaching 5.09% for tax years beginning in 2026, then 4.99% for tax years beginning in 2027—until the rate reaches a terminal rate of 4.99 percent. These annual reductions are contingent upon meeting specific revenue trigger conditions evaluated each year by the Georgia Office of Planning and Budget.

Revenue trigger conditions. The 2025 Georgia legislative session report summarizing HB 111 describes a revenue-trigger mechanism tied to state revenue growth and reserve levels, though the specific statutory language is not reproduced in the summary. According to secondary sources describing the enacted bill, the Georgia Office of Planning and Budget must evaluate by December 1 each year whether conditions tied to the Governor's revenue estimate, net revenue collection trends over the preceding three fiscal years, and the balance of the Revenue Shortfall Reserve have been met. If the conditions are not satisfied in a given year, the next scheduled rate reduction is delayed by one year. The evaluations continue until the rate reaches 4.99 percent.

The session report confirms that HB 111 amended O.C.G.A. § 48-7-20 to lower the individual income tax rate from 5.39% to 5.19% effective January 1, 2025. Georgia's corporate income tax rate historically has mirrored the individual income tax rate structure under the flat-rate regime. The specific revenue-trigger criteria and the statutory text governing corporate income tax rates warrant confirmation from the codified statute or official Georgia Department of Revenue guidance.

As of June 2026, primary-authority confirmation of the 2026 trigger evaluation and whether the rate remains 5.19% or decreased to 5.09% for tax years beginning in 2026 is not available in official Georgia Department of Revenue publications accessible online. Practitioners should verify the current-year rate with the Department of Revenue or consult the codified amendments to O.C.G.A. Title 48, Chapter 7.

Source: 2025 Georgia House of Representatives Session Report, HB 111 (Final Bill Summary) Source: Corporate Income and Net Worth Tax, Georgia Department of Revenue

A corporation is subject to Georgia corporate income tax if it owns property in Georgia, does business in Georgia, or receives income from Georgia sources. "Doing business" means engaging in any activities or transactions within Georgia for financial profit or gain. Having an employee in the state generally creates nexus. Corporations that only solicit orders for sales of tangible personal property, with orders approved and filled from outside Georgia via common carrier, may be protected from income tax under federal Public Law 86-272, but this exemption does not apply if employees perform activities beyond mere solicitation. P.L. 86-272 does not exempt corporations from Georgia's net worth tax, which has separate nexus standards.

Source: C Corporations - FAQ, Georgia Department of Revenue

Georgia taxable net income starts with a corporation's federal taxable income and applies Georgia-specific additions and subtractions before apportionment. The modifications address income items that are treated differently for federal and state tax purposes. The major additions and subtractions are set forth in O.C.G.A. (Official Code of Georgia Annotated) § 48-7-21(b).

State and local income tax addback. Corporations must add back to taxable income any taxes on or measured by net income or net profits that were deducted in computing federal taxable income. This includes income taxes paid or accrued to the United States, any foreign country, any state except Georgia, and any political subdivision of a state, territory, or foreign country. The addback ensures Georgia does not subsidize other jurisdictions' income taxes. Because Georgia's own income tax is not deductible for federal purposes, no addback is required for Georgia income tax.

Related-party intangible and interest expense addback. Under O.C.G.A. § 48-7-28.3, a corporation must add back otherwise deductible interest expenses and costs and intangible expenses and costs that are directly or indirectly paid, accrued, or incurred to or in connection with one or more related members. "Intangible expenses and costs" include royalty, patent, technical, and copyright fees, as well as expenses for the acquisition, use, maintenance, management, ownership, sale, exchange, or disposition of intangible property such as patents, trademarks, copyrights, and trade secrets. "Interest expenses and costs" include amounts deductible under Internal Revenue Code Section 163 to the extent they relate to intangible property. A "related member" is generally defined by reference to the ownership standards in IRC Section 267 or Section 1563, typically requiring at least 50 percent common ownership.

The addback is required before income is apportioned. Georgia Regulation 560-7-7-.05 (formerly designated as 560-7-3-.05) clarifies that both direct and indirect related-member costs must be added back, and taxpayers must complete Form IT-Addback to report the adjustment.

Exceptions to the related-party addback. The addback under O.C.G.A. § 48-7-28.3 may be reduced (but not below zero) to the extent the corresponding expenses are (1) received as income in an arm's length transaction by the related member, and (2) such income is allocated or apportioned to and taxed by Georgia or another state that imposes a tax on or measured by the income of the related member. For this purpose, "state" excludes states where the taxpayer and related member file a consolidated or combined return that eliminates the tax effects of the intercompany transaction. A separate exception applies if the expenses are paid to a related member domiciled in a foreign nation with a comprehensive income tax treaty with the United States, the transaction has a valid business purpose, and the amounts were determined at arm's length rates.

Other-state municipal bond interest addback. When interest income is derived from obligations of any state or political subdivision other than Georgia or its political subdivisions, the interest must be added to taxable income to the extent it was not included in gross income for federal purposes. Conversely, interest or dividends on obligations of the United States and its territories, possessions, authorities, commissions, or instrumentalities must be subtracted from taxable income to the extent such amounts are includable in gross income for federal purposes but exempt from state tax under federal law.

U.S. obligations exempt from federal tax but not state tax. Interest or dividends on obligations of any authority, commission, instrumentality, territory, or possession of the United States that are exempt from federal income tax but not from state income tax under federal law must be added to taxable income.

Depreciation adjustments. Georgia taxable income may be adjusted, at the taxpayer's election, with respect to federal depreciation deductions as provided in O.C.G.A. § 48-7-39. This provision permits certain decoupling from federal bonus depreciation and Section 179 expensing rules, though Georgia has conformed to many federal provisions over time.

Adjustments for non-Georgia losses and deductions. No portion of any deductions or losses that occurred in a year in which the taxpayer was not subject to Georgia taxation, including net operating losses, may be deducted in any tax year. When federal adjusted gross income or net income includes such deductions or losses, an adjustment deleting them must be made under rules established by the Commissioner.

Source: O.C.G.A. § 48-7-21 Source: O.C.G.A. § 48-7-28.3 Source: Ga. Comp. R. & Regs. 560-7-7-.05

Georgia uses a single-factor apportionment formula to determine the portion of a multistate corporation's income subject to Georgia tax. The formula uses only gross receipts—not property or payroll. The apportionment percentage is calculated by dividing Georgia gross receipts by total gross receipts everywhere. For sales of tangible personal property, receipts are sourced to Georgia if products are shipped or delivered to customers within the state.

Source: 2025 IT-611 Corporate Income Tax Instruction Booklet, Georgia Department of Revenue

Georgia sources gross receipts to the state using different rules depending on whether the receipts are from sales of tangible personal property or from other business activities, including services.

Tangible personal property. For corporations whose net business income is derived principally from the manufacture, production, or sale of tangible personal property, receipts are deemed to have been derived from business done within Georgia only if the receipts are received from products shipped to customers in Georgia or delivered within Georgia to customers. In determining the gross receipts within Georgia, receipts from sales negotiated or effected through offices of the taxpayer outside Georgia and delivered from storage in Georgia to customers outside Georgia are excluded from the numerator.

Services and other business activities. For corporations whose net business income is derived principally from business other than the manufacture, production, or sale of tangible personal property, the term "gross receipts" means all gross receipts received from activities which constitute the taxpayer's regular trade or business. Gross receipts are in Georgia if the receipts are derived from customers within this state or if the receipts are otherwise attributable to this state's marketplace.

Under the regulations, "customers within this state" means:

• A customer that is engaged in a trade or business and maintains a regular place of business within Georgia, or
• A customer that is not engaged in a trade or business whose billing address is in Georgia.

A "regular place of business" means an office, factory, warehouse, or other business location at which the customer regularly conducts business. A "billing address" means the location indicated in the books and records of the taxpayer as the address of record where any statement or bill relating to a customer's account is mailed.

Partial benefit. If a customer receives only a portion of the benefit of a service in Georgia, the gross receipts are assigned to Georgia in proportion to the extent the customer benefits from the service in Georgia. For example, the regulation illustrates that if a pest control company enters into one contract covering 100 apartment units in Georgia and 400 apartment units in another state, 20% (100/500) of the gross receipts from the contract are attributable to Georgia, presuming the number of apartment units is the best measure of the extent to which the recipient received benefit of the service in Georgia in the absence of more accurate records.

Mixed receipts. Where a taxpayer's gross receipts are derived from both activities described in paragraph (1) (tangible personal property) and paragraph (2) (other business), gross receipts shall include gross receipts from both categories, with each category attributed to Georgia based upon its respective sourcing rule.

Source: O.C.G.A. § 48-7-31 Source: Ga. Comp. R. & Regs. 560-7-7-.03 Source: 2023 IT-611S S Corporation Income Tax Instruction Booklet, Georgia Department of Revenue

Georgia imposes a separate corporate net worth tax on corporations in addition to the corporate income tax. This tax is calculated on the corporation's net worth — defined as the sum of issued capital stock, paid-in surplus, and earned surplus — and is assessed annually. Georgia is one of the few states that continues to impose this type of tax.

Tax amounts and exemption. For net worth years beginning on or after January 1, 2018, corporations with net worth of $100,000 or less are not subject to tax but must still file a return. The tax is imposed according to a graduated bracket schedule established in O.C.G.A. § 48-13-73:

• Over $100,000 and not exceeding $150,000: $125.00
• Over $150,000 and not exceeding $200,000: $150.00
• Over $200,000 and not exceeding $300,000: $200.00
• Over $300,000 and not exceeding $500,000: $250.00
• Over $500,000 and not exceeding $750,000: $300.00
• Over $750,000 and not exceeding $1,000,000: $500.00
• Over $1,000,000 and not exceeding $2,000,000: $750.00
• Over $2,000,000 and not exceeding $4,000,000: $1,000.00
• Over $4,000,000 and not exceeding $6,000,000: $1,250.00
• Over $6,000,000 and not exceeding $8,000,000: $1,500.00
• Over $8,000,000 and not exceeding $10,000,000: $1,750.00
• Over $10,000,000 and not exceeding $12,000,000: $2,000.00
• Over $12,000,000 and not exceeding $14,000,000: $2,500.00
• Over $14,000,000 and not exceeding $16,000,000: $3,000.00
• Over $16,000,000 and not exceeding $18,000,000: $3,500.00
• Over $18,000,000 and not exceeding $20,000,000: $4,000.00
• Over $20,000,000 and not exceeding $22,000,000: $4,500.00
• Over $22,000,000: $5,000.00

The maximum net worth tax is $5,000.

Due date and payment timing. The corporate net worth tax is due on the first day of the tax period, meaning it is an advance payment for the year ahead. C corporations must file a return and pay the tax on the 15th day of the fourth month following the beginning of the tax period. S corporations must file and pay on the 15th day of the third month following the beginning of the tax period. The net worth tax return is combined with the state corporate income tax return (Form 600 for C corporations, Form 600-S for S corporations).

Initial net worth tax. All corporations doing business in Georgia for the first time must file an initial net worth return. For C corporations with net worth years beginning on or after January 1, 2017, the initial return is due on the 15th day of the fourth month after incorporation or qualification in the state. For S corporations (and for C corporations with net worth years beginning before January 1, 2017), the initial return is due on the 15th day of the third month after incorporation or qualification. The net worth reported on the initial return is as of the date of incorporation or qualification. If the initial period from incorporation or qualification to the end of the first income tax year is less than six months, the tax due is 50 percent of the annual amount; otherwise, a full year's net worth tax is due.

Apportionment. A Georgia corporation or a domesticated foreign corporation is liable for net worth tax on 100 percent of its taxable net worth. For corporations incorporated in states other than Georgia, the net worth is apportioned using a ratio computed with property and gross receipts within Georgia divided by total property and gross receipts everywhere. For the property portion of the apportionment ratio, the "everywhere amount" is the ending balance sheet asset amount from the federal income tax return, and the "within Georgia amount" is calculated using assets owned in Georgia. Tangible and intangible assets — including cash, accounts receivable, allowance for bad debts, and accumulated depreciation — are all included in the property factor for net worth tax purposes.

Entities not subject to net worth tax. Partnerships are not subject to Georgia net worth tax. A single-member LLC is not subject to Georgia net worth tax. However, if the owner of a single-member LLC is a corporation, the corporation is subject to Georgia net worth tax if the single-member LLC does business or owns property in Georgia. A Qualified Subchapter S Subsidiary (QSSS) and its parent corporation each file separate net worth tax returns.

Public Law 86-272 does not apply. The federal protection under Public Law 86-272, which shields certain corporations from state income tax when their activities are limited to solicitation of orders for sales of tangible personal property, does not exempt corporations from Georgia's net worth tax. Net worth tax has separate nexus standards and applies even when income tax does not.

Source: O.C.G.A. § 48-13-73 Source: O.C.G.A. § 48-13-76 Source: O.C.G.A. § 48-13-77 Source: Corporate Income and Net Worth Tax, Georgia Department of Revenue Source: Net Worth Tax for Corporations - FAQ, Georgia Department of Revenue

Georgia permits certain affiliated corporations to elect to file a consolidated Georgia corporate income tax return, eliminating the prior-approval requirement that existed before 2023. This election allows members of a Georgia affiliated group to combine and report taxable income or loss on a single return while separately computing each member's apportioned income.

Eligibility: Georgia affiliated group definition. A "Georgia affiliated group" is a group of corporations in which each member: (1) is a member of an affiliated group as defined in Internal Revenue Code Section 1504 that files a consolidated federal corporate income tax return; (2) is subject to taxation under Georgia's corporate income tax provisions (O.C.G.A. Chapter 7 of Title 48), even after the application of Public Law 86-272; (3) was a member of the affiliated group for the entire taxable year, or was a member for a portion of the year if the member was subject to Georgia corporate income tax during the entire portion of the year during which it was not a member of the federal consolidated group; (4) apportions Georgia taxable income or loss separately for each corporation; (5) allocates taxable income or loss separately for each corporation; (6) computes apportionable income or loss utilizing separate apportionment factors for each corporation; and (7) combines and reports taxable income or loss on a single return for the Georgia affiliated group which includes all members of the affiliated group included on the federal consolidated corporate income tax return that are eligible to be included in the Georgia affiliated group.

Election mechanics and timing. A Georgia affiliated group may elect to file a Georgia consolidated return on an originally filed return, including extensions, if applicable. The election is made by the designated parent corporation marking the "Consolidated GA Parent Return" checkbox on Form 600. Each subsidiary member included in the consolidated return must complete Form 600 and mark the "GA Consolidated Subsidiary" checkbox and provide the federal employer identification number of the Georgia parent company. Under no circumstances may the Georgia Department of Revenue compel a taxpayer to file a Georgia consolidated return if the taxpayer has not elected to do so.

Five-year irrevocability period. The consolidated filing election is irrevocable and binding on both the Georgia affiliated group and the Department of Revenue for five taxable years. The election automatically terminates after five years. Upon automatic termination, the taxpayer may re-elect to file a Georgia consolidated return, subject to the same five-year irrevocability period.

Separate computation, combined reporting. For purposes of allocation and apportionment, each member of a Georgia affiliated group is considered a separate taxpayer. Each member separately computes its Georgia taxable income or loss using separate apportionment factors. The Georgia consolidated return then combines the separately computed post-apportioned income or loss amounts of all members. Tax credits must be calculated and claimed on a separate-company basis, with limitations based on a percentage of state income tax liability computed on a separate-company basis. Net worth tax must also be reported and paid on a separate-company basis by each member.

No combined reporting under unitary concept. Georgia law expressly provides that nothing in the consolidated return provisions shall be construed as allowing or requiring the filing of combined income tax returns under the unitary business concept. Georgia remains a separate-return state; the consolidated filing election permits combination of separately computed post-apportioned income only.

Effective date and transition. House Bill 1058, which enacted the elective consolidated filing regime, was signed into law on May 5, 2022, and applies to taxable years beginning on or after January 1, 2023. Georgia affiliated groups that received permission to file consolidated returns for tax years beginning before January 1, 2023 under the prior approval-based regime may either (1) continue to file consolidated returns under the previous criteria and remain bound by the terms of the prior grant of permission; (2) terminate their election under the previous criteria and elect to file a Georgia consolidated return under the new five-year irrevocable election; or (3) cease filing consolidated returns and file separately. The Georgia Department of Revenue promulgated Regulation 560-7-3-.13, effective for taxable years beginning on or after January 1, 2023, to implement the statutory provisions.

Source: O.C.G.A. § 48-7-21(b)(7.1) Source: Ga. Comp. R. & Regs. 560-7-3-.13 Source: Instructions to File Consolidated Returns, Georgia Department of Revenue