Due diligence

Every claim is verifiable. Here is the legal and structural basis for each one.

Aurum does not ask clients to take anything on trust. The following documentation covers the legal basis for all tax claims, the complete entity and custody structure, the banking relationship model, and the evidence base for every yield and treaty figure cited on this site.

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T3RRA Ltd is an independent global platform that creates and distributes tokenised real estate assets using the L3RS-1 regulated asset standard. It is not an Aurum subsidiary or white-label infrastructure provider — it is a separate company with its own products, clients, and distribution channels. Aurum uses T3RRA's technology stack and offers T3RRA-originated instruments to its HNWI and UHNWI clients as one of T3RRA's distribution channels. The two companies share a founding principal and a common compliance standard but are legally and operationally distinct. Client assets are never held on T3RRA or Aurum balance sheets. Each client investment is structured through a Georgian Special Purpose Vehicle (SPV) — a single-purpose Georgian LLC or JSC registered specifically for that investment. The SPV holds the underlying real asset (commercial property, gold, private credit, or digital asset). The client holds equity in the SPV directly, or through a nominee structure where required by jurisdiction. The SPV is separated from T3RRA and Aurum at every layer. There is no commingling of client funds. The platform earns a platform fee from the client — it does not participate in SPV economics. Custody of tokenised title is maintained through the L3RS-1 protocol deployed on Aurum's private institutional chain, with MPC (Multi-Party Computation) key management across geographically distributed signers. No single party holds unilateral access to client assets. Reporting flows from the SPV → the client dashboard → the client's home-country tax advisor, structured to be fully CRS-compliant and FATF-clean.

T3RRA Ltd (technology) · Georgian SPV per investment · no commingling · MPC custody · CRS-reportable · FATF-clean

0% personal income tax on foreign-source income: Georgian Tax Code, Article 82.2.u. Georgian tax residents are exempt from personal income tax on income that does not have a Georgian source. This is the base statute, not a ruling or concession. It does not require ministerial approval to maintain and has been in force continuously since the Tax Code was enacted. 0% wealth tax, 0% inheritance tax, 0% gift tax: Georgian law does not contain a wealth tax, inheritance tax, or gift tax. There is no statute creating these obligations. They do not exist as legal categories. 0% crypto CGT and 0% VAT on personal crypto disposals: Ministry of Finance of Georgia, Decision N201, June 2019. Formally classified income from personal crypto asset sales as non-Georgian-source income, placing it outside the scope of Georgian personal income tax and VAT for Georgian tax residents. 0% CGT on shares (non-Georgian-source): Same statutory basis as Article 82.2.u. Gains from disposal of non-Georgian assets do not have Georgian source and are exempt. 5% CGT and 5% dividend tax on Georgian-source assets: Georgian Tax Code standard rates for resident individuals on Georgian-source gains and distributions. Aurum commercial real estate yields are structured to return cash flow rather than capital gains where possible, minimising exposure to this rate. Georgian tax residency — legal basis: A foreign national becomes a Georgian tax resident by spending 183+ calendar days in Georgia in a calendar year, OR by obtaining HNWI status under Georgian Tax Code Article 34(6) and Ministry of Finance Decree #60 (March 2023) — which requires ownership of qualifying Georgian assets worth USD 500,000+ and proof of global wealth of GEL 3,000,000+. The HNWI route does not require 183 days of physical presence.

Georgian Tax Code Art. 82.2.u · MoF Decision N201 June 2019 · Art. 34.1 HNWI route · 0% IHT by absence of statute · reviewed by international counsel

Client private banking is established with TBC Bank (LSE: TBCG) or Bank of Georgia (LSE: BGEO) — both London Stock Exchange-listed, Basel III regulated, audited by Big Four firms, and SWIFT-connected through major European correspondent banks. The banking relationship is direct between the client and the bank. Aurum introduces the client and assists with onboarding documentation but does not hold client funds, is not a signatory on client accounts, and cannot access client balances. Accounts are multi-currency (GEL, USD, EUR, GBP) with SWIFT international transfer capability. There are no capital controls on outbound transfers — Georgia has never imposed capital controls in its 30+ years as a sovereign state, including through the 2008 war, the 2014 Russia-Ukraine crisis, and the COVID-19 period. The Georgian deposit guarantee scheme covers GEL 50,000 per depositor. For HNWI clients, the protection is structural: TBC Bank and Bank of Georgia are internationally listed institutions with capital ratios well above Basel III minimums and no history of bail-in or depositor loss. Both banks are audited by Deloitte and EY respectively and publish full IFRS accounts quarterly. Client SPV accounts are separate from personal accounts — both held at the same institutions, but in the SPV's name. The SPV account holds rental income, asset sale proceeds, and distributions before they are transferred to the client's personal account.

TBC Bank: TBCG.L · Bank of Georgia: BGEO.L · Basel III · Deloitte + EY audited · SWIFT · no capital controls ever imposed · 30+ years Georgian independence

Each Aurum vault corresponds to a specific underlying real asset — a commercial property, a gold allocation, a private credit position, or a digital asset custody position. Every vault is legally a separate Georgian SPV. The SPV is a Georgian LLC (Shps) or JSC (Sss) registered with the National Agency of Public Registry. It holds clean legal title to the underlying asset. Property title is registered in the Georgian public land registry, which is blockchain-enabled and fully searchable online. There is no hidden ownership structure. The SPV issues tokenised equity to investors proportionate to their investment. These tokens represent real equity claims, not synthetic derivatives. They are governed by L3RS-1 — which enforces KYC/AML at the protocol level, requires regulatory verification before any transfer, and prevents transfers to non-verified counterparties. Vault yields are derived from underlying asset cash flows: commercial rental income (7–12% APY for Tbilisi CBD commercial property per TBC Capital 2024 research), gold price appreciation (custodied with allocated physical holding), or private credit interest. Yields are distributed to the SPV and then to token holders on a defined schedule. No yield is synthetic or manufactured through financial engineering. Minimum investment per vault: USD 25,000. Minimum total allocation: USD 1,000,000. Application fee: USD 3,500 (nonrefundable). Onboarding fee: USD 100,000 – 250,000 (on approval, scaled to allocation — see Platform page for full schedule).

Georgian LLC/JSC · public land registry · tokenised equity (not derivatives) · L3RS-1 protocol · TBC Capital yield data 2024 · USD 25K minimum per vault

MPC (Multi-Party Computation) custody means that the private keys controlling on-chain asset title are never held in a single location or by a single party. Keys are split across a minimum of three geographically separated signers using threshold cryptography — requiring any two of three signers to authorise any transaction. No single signer — not Aurum, not the client, not any third party — can unilaterally move assets. This is the institutional standard. It eliminates single-point-of-failure risk, eliminates insider theft risk, and eliminates key loss risk. It is the custody model used by Fidelity Digital Assets, Coinbase Custody, and Anchorage Digital for institutional clients. On-chain title records are maintained through L3RS-1 — the Layer-3 Regulated Asset Standard governed by the independent L3RS Foundation and authored by Dr. Zurab Ashvil. L3RS-1 has a six-year production track record: Bank of England CBDC Sandbox (June 2020), AgriDex (October 2020), Fiat-on-Chain (August 2022), and Cleverjet.io (February 2024). The National Bank of Georgia is proceeding through the Foundation's institutional ratification pathway. L3RS-1 enforces 11 formal protocol invariants (I₁–I₁₁), including: identity binding at the protocol level (not application level), pre-settlement compliance verification, transaction threshold rules, atomic settlement, and immutable audit trail. Every state transition is verifiable on-chain without relying on Aurum as an intermediary. For physical assets, custody is dual-layer: on-chain tokenised title + off-chain physical custody with audited third-party custodians. For gold: LBMA-standard allocated storage in Zurich. For art and collectibles: specialist fine art custodians with full insurance.

MPC threshold custody (2-of-3) · L3RS Foundation governed · T3RRA certified · NBG ratification pathway · LBMA gold custody Zurich · 11 formal invariants

7–12% APY commercial real estate yield (projected, not guaranteed): Source: TBC Capital Commercial Real Estate Research, 2024. Covers Tbilisi CBD office, retail, and logistics properties. The 7% floor represents stabilised assets with creditworthy anchor tenants on triple-net leases. The 12% ceiling represents newly completed assets with initial lease-up premium. Aurum targets the 7–10% range for early vaults to prioritise yield stability over maximum return. These are projected gross yields before Georgian income tax, which is 0% on foreign-source income for Georgian tax residents. Projected yields are based on current market data and are not guaranteed. 3.2% London prime residential yield: Source: Knight Frank Prime Yield Monitor, Q4 2024. London Zone 1–2 residential. Before UK income tax (45% for additional rate taxpayers), leaving a net yield of approximately 1.7%. 58 double tax treaties: Source: Georgian Ministry of Finance, active treaty register, March 2026. Covers 58 jurisdictions including UK, Germany, France, UAE, Netherlands, Switzerland, Austria, and the full CIS. Treaty texts are publicly available via the Georgian MoF website. FATF compliance — February 2024: Source: MONEYVAL (Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism), Fifth Round Mutual Evaluation Report on Georgia, adopted February 2024. Georgia achieved compliant or largely compliant ratings on 37 of 40 FATF recommendations — one of the strongest first-round results in the MONEYVAL region. EU DCFTA — 2014: Source: Association Agreement between the European Union and Georgia, including Deep and Comprehensive Free Trade Area provisions, signed June 2014, provisionally applied September 2014, fully ratified July 2016. World Bank Ease of Doing Business — 7th globally: Source: World Bank Doing Business Report, most recent edition prior to discontinuation. Georgia ranked 7th out of 190 economies overall.

Complete 58 DTT Treaty Network

CountryIn ForceDividendsInterestRoyalties
Western Europe
Austria01 Mar 200610% / 0%0%0%
BelgiumMLI5% / 15%10%5% / 10%
Bulgaria01 Jul 199910%10%10%
CroatiaMLI5%5%5%
CyprusMLI0%0%0%
Czech RepublicMLI5% / 10%8%0–10%
Denmark23 Dec 20080–10%0%0%
Estonia27 Dec 20070%0%0%
FinlandMLI0–10%0%0%
FranceMLI0–10%0%0%
Germany21 Dec 20070–10%0%0%
GreeceMLI8%8%5%
HungaryMLI0% / 5%0%0%
IcelandMLI5% / 10%5%5%
IrelandMLI0–10%0%0%
Italy19 Feb 20045% / 10%0%0%
LatviaMLI0–10%5%5%
LiechtensteinMLI0%0%0%
LithuaniaMLI5% / 15%10%10%
LuxembourgMLI0–10%0%0%
Malta19 Dec 20090%0%0%
NetherlandsMLI0–15%0%0%
NorwayMLI5% / 10%0%0%
Poland14 Apr 20235%5%5%
PortugalMLI5% / 10%10%5%
Romania15 May 19998%10%5%
San MarinoMLI0%0%0%
SerbiaMLI5% / 10%10%10%
SlovakiaMLI0%5%5%
SloveniaMLI5%5%5%
Spain01 Jul 20110% / 10%0%0%
Sweden26 Jul 2014
Switzerland07 Jul 201110% / 0%0%0%
United KingdomMLI0% / 15%0%0%
CIS & Eastern Europe
Armenia03 Jul 20005% / 10%10%5%
Azerbaijan06 Jun 199810%10%10%
Belarus24 Nov 20155% / 10%5%5%
Kazakhstan05 Jul 200015%10%10%
Kyrgyzstan29 May 20235% / 10%0–5%5–10%
Moldova17 Apr 20185%5%5%
Turkmenistan26 Jan 200010%10%10%
Ukraine01 Apr 19995% / 10%10%10%
Uzbekistan20 Oct 19975% / 15%10%10%
Middle East & Gulf
Bahrain01 Aug 20120%0%0%
Egypt20 Dec 201210%10%10%
IsraelMLI0% / 5%5%0%
Kuwait14 Apr 20130% / 5%0%10%
Qatar11 Mar 20110%0%0%
Saudi Arabia01 Apr 20190% / 5%0–5%5–8%
United Arab Emirates28 Apr 20110%0%0%
Asia-Pacific
China10 Nov 20050–10%10%5%
Hong Kong01 Jul 20215%5%5%
IndiaMLI10%10%10%
Japan23 Jul 20215% / 10%5%0%
SingaporeMLI0%0%0%
South KoreaMLI5% / 10%0–10%5–10%
Near East
Iran14 Feb 20015% / 10%10%5%
Turkey15 Feb 201010%10%10%

MLI = treaty updated under the OECD Multilateral Instrument (ratified by Georgia, December 2018). Source: Georgian Ministry of Finance · mof.ge/en/doubleTaxation · Verified March 2026.

Note: No double tax treaty exists between Georgia and the United States, Canada, or Australia. Residents of these jurisdictions should obtain independent cross-border tax advice.

TBC Capital 2024 · Knight Frank Q4 2024 · MoF DTT register March 2026 · MONEYVAL Feb 2024 · EU-Georgia AA July 2016 · World Bank EoDB

L3RS-1 is the Layer-3 Regulated Asset Standard — an open, royalty-free specification for regulated digital asset behaviour, governed by the L3RS Foundation (l3rs.foundation), an independent, vendor-neutral standards body. The standard was authored by Dr. Zurab Ashvil, whose compliance architecture development began in 2013. It was published as a stable open standard on 24 February 2026 following a 60-day public comment period with submissions from 47 organisations across 12 jurisdictions. L3RS-1 is not a T3RRA product and is not an Aurum product. It is an open standard governed by the L3RS Foundation — independent of any single vendor, platform, or jurisdiction. T3RRA is the first certified commercial deployment. Aurum's vault instruments are issued on that certified infrastructure. L3RS-1 defines 11 protocol invariants — formal mathematical constraints that every compliant asset must satisfy at all times. These are not application-level checks that can be bypassed by a developer. They are enforced at the protocol level, meaning compliance is a property of the system architecture, not a promise made by the platform operator. The 11 invariants cover: (I₁) Identity binding — every asset holder is KYC-verified at the protocol level. (I₂) Access control — role-based permissions enforced cryptographically. (I₃) Pre-settlement verification — compliance checked before every transaction executes. (I₄) Compliance state machine — formal FSM with verified state transitions. (I₅) Transaction threshold rules — hard limits on position size and transfer velocity. (I₆) Temporal constraints — time-locked settlement and holding periods. (I₇) Counterparty validation — both sides verified before atomic settlement. (I₈) Cross-chain consistency — state synchronised across all chains. (I₉) Atomic settlement — all-or-nothing execution, no partial fills. (I₁₀) Governance override — regulator intervention hooks codified in protocol. (I₁₁) Immutable audit trail — every state change permanently recorded. Verified deployments: Bank of England CBDC Sandbox (June 2020), AgriDex (October 2020), Fiat-on-Chain (August 2022), and Cleverjet.io (February 2024).

BoE CBDC Sandbox 2020 · AgriDex 2020 · Fiat-on-Chain 2022 · Cleverjet 2024 · NBG under evaluation

CRS (Common Reporting Standard) compliance: All Aurum client structures are designed to be fully reportable under CRS. Georgian financial institutions are CRS-reporting jurisdictions. Client account information is reported to the Georgian Revenue Service, which exchanges information with treaty partner tax authorities on an automatic basis. There is no opacity. Aurum does not offer or facilitate any structure designed to avoid CRS reporting. Clients are expected to disclose Georgian accounts and assets to their home-country tax authorities — Aurum's structures are designed to support this disclosure, not complicate it. Annual client reporting: Each client receives an annual report covering: SPV financial statements (audited where required by investment size), vault performance vs target yield, asset valuation (independent third-party appraisal), tax position summary prepared by Georgian tax counsel, and CRS reporting confirmation. The client dashboard provides real-time access to all of the above. Exit mechanics: Vault positions can be exited through: (a) secondary market transfer to another L3RS-1-compliant investor, (b) SPV wind-down and asset sale on the Georgian property market, or (c) redemption at net asset value where a liquidity facility is available. Georgian law imposes no exit tax. Georgian tax residency lapses naturally if the client no longer meets the 183-day or HNWI threshold — there is no formal exit process, no exit charge, and no minimum holding period enforced by Georgian law. Aurum imposes a minimum recommended holding period of 24 months per vault position, after which positions may be exited or reallocated without platform penalty. This is a commercial recommendation, not a legal lock-up.

CRS-compliant · automatic exchange of information · annual audited SPV accounts · secondary market exit · no Georgian exit tax · 24-month recommended minimum

This section constitutes the evidence and legal basis for all material claims made on this site. It does not constitute legal or tax advice. Clients are strongly encouraged to seek independent advice from qualified legal and tax counsel in their home jurisdiction before making any investment or relocation decision. Aurum engages international legal counsel alongside local Georgian tax counsel. Individual legal and tax positions vary.

Common questions

The questions every serious client asks. Answered directly.

Political risk

"Georgia's political situation concerns me."

This is the right question to ask and we raise it ourselves. The current Georgian government has distanced itself from EU accession talks — a political decision with real geopolitical consequences. What it has not done, and what no Georgian government has ever done, is touch the tax code, impose capital controls, or interfere with the banking system. TBC Bank (TBCG.L) and Bank of Georgia (BGEO.L) have operated through every Georgian political crisis since 1991 and remained fully functional, LSE-listed, and Basel III compliant throughout. The territorial tax system is codified law, not a concession — it does not require political goodwill to maintain.

Mitigation: LSE-listed banks · SPV isolation · tax law independent of government policy · no capital controls ever imposed

Banking resilience

"What happens to my money if the system comes under stress?"

TBC Bank and Bank of Georgia are internationally listed, Basel III regulated, with full SWIFT correspondent relationships through major European clearing banks. Both hold capital ratios above Basel III minimums and are audited by Big Four firms. Georgia has never imposed capital controls in its 30+ year history — including through the 2008 war, the 2014 Russian sanctions crisis, and the COVID shock. Client assets within Aurum vaults are held in SPV-isolated structures, not on bank balance sheets.

TBC Bank: TBCG.L · Bank of Georgia: BGEO.L · Basel III · Big Four audited · zero capital control history

Exit clarity

"What if I need to leave or restructure in the future?"

Georgia imposes no exit tax. Selling Georgian assets, closing a Georgian bank account, or ending Georgian tax residency is straightforward and involves no punitive exit event. Vault positions can be sold on the secondary market. Georgian tax residency simply lapses if the 183-day rule is not met — there is no formal exit process required. There is no lock-in.

No exit tax · no capital controls · vault liquidity via secondary market · residency lapses naturally

Home country compliance

"Will this create problems with my home country tax authority?"

Georgia has 58 double tax treaties covering every major jurisdiction including the UK, Germany, France, UAE, and the full CIS. Aurum structures every client arrangement to be fully reportable and fully compliant with home-country disclosure obligations under CRS. We engage international legal counsel alongside local tax counsel. This is onshore, transparent, and treaty-backed — the opposite of an offshore structure that relies on opacity.

58 DTTs · CRS-compliant · full documentation · reviewed by international counsel

Legacy and succession

"How does this work across generations?"

Consider a client with a USD 20M estate. In the UK, that estate faces 40% IHT above the £325,000 nil-rate band — approaching USD 8M in tax. In Georgia, the same estate passes to the next generation with zero inheritance tax, zero gift tax, and zero wealth tax. Over two generations, the compounding of that saving — reinvested at 7–12% commercial yields — is transformational.

0% IHT · 0% gift tax · USD 8M saving on USD 20M estate vs UK · family residency structuring available

Zero days required

"How many days do I need to spend in Georgia to qualify for HNWI tax residency?"

Zero. The HNWI programme under Ministry of Finance Decree #60 has no minimum physical presence requirement. Standard Georgian tax residency requires 183 days in any 12-month period. The HNWI route is different: it is a purely financial qualification. You do not need to visit, stay in, or be physically present in Georgia at any point during the year to obtain or maintain HNWI tax residency status. Qualification is based entirely on your asset position and economic connection to the country.

MoF Decree #60 (2023) · Zero days required · Purely financial qualification · USD 500K Georgian assets + global wealth criteria

Source-country tax

"Does Georgian HNWI tax residency mean I stop paying tax in my home country?"

Not automatically — and this distinction matters. Georgian HNWI residency establishes Georgia as your country of tax residence and means Georgia taxes your foreign-source income at 0%. What it does not do is prevent other countries from taxing income that originates within their borders. A company in Germany paying you dividends will still withhold German tax before the money reaches you. Rental income from a UK property is still taxable in the UK. That is source-country taxation, and it applies regardless of where you are tax resident. More significantly: other countries have their own rules for establishing tax residency. If you maintain a permanent home in France, spend substantial time in Italy, or keep your family and business centred in any other jurisdiction, that country may assert its own residency claim over you — and your Georgian certificate will not automatically override it. Double tax treaties between Georgia and those countries contain tie-breaker rules to resolve conflicts, but the tie-breaker follows genuine life connections, not paperwork. Georgian HNWI residency is most powerful for individuals who are genuinely internationally mobile, have already reduced or severed tax residency ties to a previous high-tax jurisdiction, need a recognised tax residency certificate from a stable jurisdiction, and structure their financial life across multiple countries without crossing residency thresholds in any one of them. Every situation is different. Aurum's advisors will assess your specific position before recommending any course of action.

Source-country withholding still applies · DTT tie-breaker rules based on genuine connections · best suited for genuinely mobile individuals

Dual residency claims

"What happens if both Georgia and another country claim me as a tax resident?"

If two countries both assert tax residency over you under their respective domestic laws, the Double Tax Treaty (DTT) between those countries determines which one prevails. Georgia has DTTs with 58 countries. The tie-breaker provisions in these treaties typically look at, in order: where you have a permanent home; where your personal and economic relations are closer (centre of vital interests); where you habitually reside; and citizenship. If your genuine life — your home, family, business activity — is centred in another country, the tie-breaker will likely favour that country, not Georgia, even if you hold a Georgian HNWI certificate. This is why the Georgian HNWI programme works for people who are genuinely internationally mobile, not as a paper overlay on an otherwise unchanged life. For countries without a Georgian DTT — including the United States for US citizens, who are taxed on worldwide income regardless of where they reside — the analysis is more complex and requires specific advice.

58 DTTs with tie-breaker provisions · centre of vital interests test · US citizens taxed on worldwide income regardless of residency

Time commitment

"I cannot commit to living in Georgia full-time."

You do not need to — in fact, you do not need to commit to any time in Georgia at all. The HNWI tax residency route has no physical presence requirement under Ministry of Finance Decree #60. A USD 500,000 investment in qualifying Georgian assets plus proof of GEL 3 million in global wealth (or 3 years of GEL 200,000+ income) establishes HNWI status. You can continue to live in London, Dubai, Singapore, or anywhere else and retain Georgian tax residency as your primary legal tax position without ever setting foot in the country.

HNWI route: Zero days required · USD 500K Georgian asset · GEL 3M global wealth · live anywhere

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