For Chinese-resident clients who have structured private wealth through trusts or foundations and hold assets in Georgia — or who chose Tbilisi as their relocation jurisdiction in recent years — the legal landscape shifted in a meaningful way in late 2026 and early 2027. Georgian courts and the National Agency of the Public Registry have moved from a position of institutional ambiguity toward a more defined, if still incomplete, framework for recognising foreign trust arrangements and foundation structures. For Chinese nationals who sit outside the common-law tradition and whose home jurisdiction does not itself employ the trust concept, these developments carry particular practical weight: they determine whether a structure built around Georgian real estate, Georgian company shares, or Georgian bank accounts will be respected as intended — or collapsed into a domestic ownership analysis that ignores the trust dimension entirely.
Until recently, Georgian private international law did not contain an explicit rule addressing the recognition of foreign trusts. Georgia is not a signatory to the Hague Convention on the Law Applicable to Trusts and on Their Recognition, and its civil code — which follows the continental civil law tradition — has no domestic trust concept. A foreign trustee seeking to register title to Georgian real estate in that capacity, or a foundation seeking to hold a Georgian participatory interest in a recognisable legal form, faced practical resistance at the registration stage. The National Agency of the Public Registry and the courts handling ownership disputes applied domestic property law categories, which resulted in trustees being registered as beneficial owners and the fiduciary character of the holding being effectively invisible to third parties and creditors.
The shift that has occurred is procedural and interpretative rather than legislative. Georgian courts, beginning with several decisions in the commercial and civil chambers during 2025 and 2026, began applying a conflict-of-laws methodology that looks to the law of the jurisdiction where the trust or foundation was constituted — the lex constitutionis — when assessing the nature of the relationship between a registered holder and the underlying beneficiaries. This does not yet amount to full recognition in the Hague Convention sense, but it means that properly documented trust arrangements governed by a recognised foreign law — British Virgin Islands, Cayman Islands, Singapore, or English law structures are the most commonly encountered — can now be characterised by Georgian courts as fiduciary rather than inherently proprietary in nature. The practical consequence is that, in insolvency or enforcement proceedings against a trustee or a foundation manager, a well-documented trust instrument may succeed in rebutting the presumption that the assets form part of the trustee's personal estate.
For Georgian registration purposes, the Public Registry has not yet issued binding guidance on how to register a trustee's title as a fiduciary holding. In practice, the approach that has worked for clients is to register in the name of the trustee with a supporting notation — a legended entry or an attached deed of trust disclosed on the public record — and to rely on the interpretative shift in case law if the fiduciary character is later challenged. This is an imperfect solution, but it reflects where Georgian practice currently stands.
The affected population is broader than it might initially appear. Chinese nationals have been among the most active foreign purchasers of Georgian real estate since 2017, and following tightened capital controls and heightened compliance scrutiny in the People's Republic, a subset of Chinese-resident high-net-worth individuals and family offices chose to restructure their Georgian holdings through offshore trust or foundation vehicles — most commonly BVI or Singapore trusts — before or shortly after relocating to Tbilisi. For this group, the developments described above are immediately relevant.
Three categories of Chinese-resident client are most directly affected. First, those who established a foreign trust or foundation and transferred Georgian real estate or company shares into it, but whose Georgian registration still shows the trustee or foundation as a straightforward legal owner — without any disclosure of the fiduciary character. For these clients, the current interpretative environment is more permissive than before, but the registration position remains vulnerable to a direct challenge by a creditor or a Georgian tax authority. Second, those who are in the process of acquiring Georgian assets and wish to take title through an offshore trust or foundation vehicle — they now have a clearer, though not codified, pathway, provided the trust instrument is well drafted and the governing law is one that Georgian courts have previously recognised. Third, Chinese nationals who have relocated to Georgia under the Virtual Zone or Small Business Status regimes and are considering succession planning for Georgian and international assets simultaneously — for this group, the absence of a Georgian domestic trust vehicle is a planning constraint that the recognition developments partially address.
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The absence of an express legislative framework creates specific risks that succession planning must account for. The most significant is forced heirship exposure. Georgian inheritance law follows the continental model and provides for reserved shares for close family members. If a Georgian court does not recognise a trust arrangement as creating a genuine separation between the trustee's personal estate and the trust fund, the assets held by the trustee in that capacity may be treated as part of the trustee's estate on death — triggering Georgian forced heirship rules in relation to assets that the settlor intended to pass outside of intestacy or testamentary succession altogether.
The interpretative shift in Georgian case law reduces, but does not eliminate, this risk. The relevant question is whether the trust instrument, its governing law, and the conduct of the trustee provide sufficient evidence to demonstrate the fiduciary character of the holding to a Georgian probate court. In the experience of practitioners working in this space, the weakest points are typically two: the trust instrument is governed by a law that Georgian courts have not previously encountered, or the trust has been administered without the operational discipline that demonstrates genuine separation — commingled accounts, no formal trustee resolutions, or a trustee who is also the settlor and effectively retained control. Chinese-resident clients who set up trust structures during the 2021–2023 period of peak relocation activity, often quickly and with limited professional input, are disproportionately represented in the second category.
Foundation structures face a related but distinct issue. Georgia does not have a domestic civil law foundation vehicle equivalent to a Liechtenstein foundation or a Cayman STAR trust. Foreign foundations seeking to hold Georgian assets must therefore operate through a Georgian representative or holding structure, and the question of whether the foreign foundation's beneficial ownership instructions will be respected is answered by the same conflict-of-laws analysis that applies to trusts. The 2025–2026 case law developments apply equally here.
"The recognition gap in Georgian law is real, but it is manageable for clients who are willing to invest in documentation rigour and take a proactive approach before a dispute or succession event arises — not after." — Nino Beridze, Contributing Regional Analyst — Georgia, Business Relocation & Tax Structuring
Three practical steps address the current exposure for clients with existing structures and for those planning new ones.
The first is a documentation audit of existing trust or foundation arrangements that hold Georgian assets. This means confirming that the trust instrument is in a form that a Georgian court would recognise as creating a genuine fiduciary relationship — which requires the governing law to be identified clearly, the trustee to be distinguished from the settlor, and any letters of wishes to be held separately from the instrument itself. Where the governing law is an unfamiliar offshore jurisdiction, consideration should be given to whether re-domiciliation to a more commonly encountered law — BVI, Singapore, or English law — is procedurally available and commercially justified.
The second is to consider the Georgian registration position. As noted above, the Public Registry has not issued formal guidance on fiduciary title registration. However, several practitioners in Tbilisi have successfully negotiated annotated registrations — where the trust character of the holding is disclosed on the title entry — on a case-by-case basis. This is worth pursuing, even where it requires a contested registration application, because a disclosed fiduciary holding is materially less vulnerable to a subsequent challenge than one that appears as an outright ownership entry.
The third concerns succession planning at the multi-jurisdictional level. Chinese-resident clients who hold assets in Georgia, in offshore vehicles, and potentially in Russia or other CIS jurisdictions — a combination that is more common among this client group than is often assumed — face a succession planning challenge that cannot be solved by a single-jurisdiction analysis. Georgian law governs the transmission of Georgian-sited assets; the offshore trust or foundation instrument governs beneficial entitlement; and the client's Chinese residence status may engage additional complications. Coordinating these layers requires counsel with visibility across all relevant dimensions. [Private Wealth & Structuring](/jurisdictions/georgia/private-wealth/) and [Succession Planning](/jurisdictions/georgia/succession/) guidance is available for clients beginning this review.
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Q: What specifically changed in Georgian law on trust recognition in 2026–2027? A: No legislative amendment was enacted. The change is interpretative: Georgian courts in 2025 and 2026 began applying a conflict-of-laws methodology that examines the law of the jurisdiction where a trust or foundation was established when characterising the relationship between a registered holder and the underlying beneficiaries. This means that a foreign trust governed by a recognised law — such as English law, BVI law, or Singapore law — may now be treated by Georgian courts as fiduciary rather than inherently proprietary in nature, reducing the risk that trust assets are treated as personal assets of the trustee in insolvency, enforcement, or succession proceedings. The National Agency of the Public Registry has not yet issued corresponding formal guidance, and the registration position remains practically challenging.
Q: Which Chinese-resident clients are most exposed to the recognition gap in Georgian law? A: The most exposed are those who transferred Georgian real estate or company participatory interests into offshore trust or foundation structures between 2021 and 2023 — often quickly and without specialist Georgian legal input — and whose Georgian registrations do not disclose the fiduciary character of the holding. For these clients, the combination of a non-disclosed trust holding and a governing law that Georgian courts have not previously encountered creates material vulnerability in both succession and creditor-enforcement scenarios. Clients who have relocated to Georgia under the Virtual Zone or Small Business Status regimes and are planning their Georgian and offshore succession simultaneously are also directly in scope.
Q: What should a Chinese-resident client with Georgian assets held through a trust do now? A: Three steps are advisable. First, commission a documentation audit of the trust instrument to verify that it would satisfy the evidentiary standard a Georgian court would apply to confirm the fiduciary character of the holding. Second, consider approaching the Public Registry to annotate the existing title entry to disclose the trust relationship. Third, review the multi-jurisdictional succession plan to ensure that the Georgian, offshore, and any Russian or CIS asset layers are addressed coherently. Specialist legal advice Georgia-focused and cross-border counsel should be engaged jointly for this exercise.
Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years and listed as a trusted adviser by the German Consulate General in Novosibirsk. The firm works with Contributing Regional Analysts in adjacent jurisdictions — including Georgia — to advise clients whose asset and succession planning spans Russia, CIS, and Caucasus jurisdictions simultaneously.
For Chinese-resident clients with Georgian asset exposure alongside Russian or CIS holdings, the firm coordinates cross-border analysis through its network of regional counsel, ensuring that succession plans, trust structures, and asset protection strategies are coherent across all relevant jurisdictions. Over 1,000 matters handled since inception, with direct partner involvement on every engagement.
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This publication is provided for informational purposes only and does not constitute legal advice under Russian or any other applicable law. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Vetrov & Partners is a Russian-qualified law firm. For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction. For advice regarding your particular situation, please contact info@vetrovpartners.com.
— Nino Beridze Contributing Regional Analyst — Georgia, Business Relocation & Tax Structuring vetrovpartners.com/contributions/