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Tourist Enterprise Status

September 30, 2026

In nineteen months, the only regulation anyone at Next has ever named to justify its demands is the apart-hotel status of Next White. This page says what that status is, what it obliges, whom it obliges, and what Next did with it.

What it is

There is no "apart-hotel status" in Georgian law. What Next means is the status of a tourist enterprise under Article 26¹ of the Tax Code, granted by the Revenue Service to the company that builds a hotel, per building, on the company's own application, under a government rule. Next's lawyer used the correct term once, in writing: "operation of the complex as a touristic enterprise".

The status is a tax arrangement. The developer sells the apartments to buyers free of VAT, on the condition that it "ensures that the hotel assets/ part of the assets are used as hotel rooms/apartments" through a contract with each buyer: a lease, a right of use, a management right, or similar. In exchange, within ten years of the building entering operation, the hotel's own VAT-taxable turnover must reach a certain quota (Article 26¹(2)(b)). If it does not, the status is cancelled and VAT falls due after all. The state forgoes 18% on the sales and expects to collect it, over ten years, on the hotel's business.

Whom it binds

Article 26¹ has one subject: the tourist enterprise. It is the enterprise that "ensures" the hotel use of the apartments, and the enterprise that "shall", after completion, designate the hotel area and meet the turnover. The buyer is mentioned once, as the other party to a contract the enterprise must obtain. Nothing in the Tax Code or in the government rule obliges a buyer to sign anything, and nothing in either mentions a contract for common-area services at all. The contracts the status cares about are those that put the apartment into hotel use.

The rule adds one detail that explains a lot. The developer is deemed to have received back an apartment, for the purposes of its VAT exemption, as soon as the buyer signs, whether or not the contract or any right under it is registered in the Public Registry. That is why my titles are clean, why Next's own lawyer could confirm that nothing is registered against them, and why no obligation could pass to me from the previous owner even if he had signed: the law never required Next to register one.

What Next said

Whatever is true in these sentences is true of Next and false of me. Next is required to obtain contracts; I am not required to give one. The condition is mandatory for Next; it is optional for every owner. The obligation arises from the status of the complex; the status is Next's. Next turned its own tax undertaking into my legal duty, and told a foreigner so, in writing, five times, without ever naming the regulation, because naming it would have shown whom it binds.

What Next knew

On July 23, 2025, my wife told Next's specialist that we would live in the apartments ourselves and not rent them out, and asked whether the management clause could be left unsigned, since when we bought "we were told that in that case there is no need to hand the apartment over to your company's management" (message). Six months later, on the day he sent me the contracts, the manager himself described Next White as "the building where you live and plan to live for a long time" (message). An apartment its owner lives in is outside the hotel management; nothing in the status prohibits that. So when Next told me that signing was mandatory, it was speaking to an owner it knew, and said it knew, would never put his apartments into its hotel. It wanted the signature for something else.

What Next wanted

The specialist had answered my wife's question the same afternoon (message): "You can sign the management contract fictitiously; it's very important for keeping the apart-hotel status". But "of course renting out isn't mandatory"; instead, "for your peace of mind, we suggest signing an agreement on the temporary suspension of the management contract". "With that you opt out indefinitely" (message).

That is the design, in Next's words: a management contract that exists for the Revenue Service, and a suspension agreement that cancels it for the owner. The contract documents the apartment's "receipt back" into the hotel, which is the condition of Next's VAT exemption; the suspension makes sure the apartment never enters it. The other signature, on the service agreement, the specialist had already explained: "there has to be a basis" for the bill. One signature to keep the tax status, one to create the debt. Neither has a legal basis, and Next's employees said so themselves.

The contracts show what else the signatures were for. The management agreement takes 40% of any rental income from the apartments. The service agreement makes every owner's fees part of the turnover Next must show the Revenue Service: under the government rule, maintenance of the hotel's infrastructure counts toward the ten-year quota. Every fee Next collects from an owner is a step toward keeping its VAT exemption. Every owner who does not pay is a step away from it. That is a motive. It is not a regulation.

Questions for the Revenue Service

The status is granted, monitored and cancelled by the Revenue Service. What I know would be relevant to it:

I do not know the answers. The Revenue Service might.

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