“Shine is not substance.”

TFPatron, the first question every critical reader asks: since when have you been in Georgia — and is GOTT WALD Holding real substance there or a shell?

PATRONI prepared this step from 2018 on, together with two friends — there were three of us. Since December 2024, GOTT WALD Holding has been an operating LLC in Georgia, with real substance: our own office, our own network. Through our platform gottwald.world we work with more than 400 people — today closer to 700 — and not as classic employees. Whoever is registered with us receives new tenders via the back end matching their profile. It is a global network — from Australia via Fiji, Peru, Canada, Europe, South Africa to Asia. But everything is steered from one point: Tbilisi.

TFWhy “Patron” and not CEO or founder?

PATRONIn my language, CEOs are paid hands on a clock that run so the numbers add up. That is not me. And “founder” is too little — having founded something does not mean living it. A Patron is someone who protects, shelters, takes care of something. Who stands for the structural and essential to endure — and to grow in a values-driven way. This is not about quick cash, but about protection: of honesty, clarity, truth, openness, transparency.

TFYou earn from this very topic. A conversation costs from €111, the holding lives on mandates. Why should anyone believe you who doesn’t already trust you?

PATRONThe €111 is more of a symbolic contribution. For mandates I charge between €500 and €700 an hour — consider the dedication with which I offer the same to any person who comes for €111. No one has to believe me. Either someone understands what I communicate — or not. That is precisely society’s problem: that we place too much value on what others think. We are values-driven, not profit-driven.

TFIsn’t the €111 conversation the funnel into the expensive mandate after all?

PATRONNo. One to one — one person with another, and together you are one and move something. The high-priced mandates do not hang on this conversation. The €111 is deliberately chosen so that the small player too gets the information the big ones rely on. A low barrier to entry — for the sole trader still sitting in Germany today, wondering whether Georgia is relevant for them, but who cannot pay €600 or €700 an hour. €111 for the chance that a life can change — that is fair.

TFWhat is the most expensive error you keep seeing among entrepreneurs?

PATRONThe belief that the system put in front of them is the only one they have to serve. Over 90 percent of SMEs in the German-speaking region think this way. There are excellent tradespeople, engineers, developers, coaches — and they are crushed by taxes, requirements and regulations to the point where they aren’t even allowed to keep up in global competition. In the DACH region the entrepreneur is the servant: he carries all the risk and earns the least of all per hour for his pure labour.

TFDubai is still seen by many as a safe haven. You see it differently.

PATRONI have been warning since 2018, 2019, since the geopolitics shifted: Dubai is built on sand. It is an illusion kept artificially alive — and when it cracks, it goes under. In 2022 I warned friends close to me. They were blind. Today the property market is under pressure. Once zero taxes, then the corporate tax came — and now they court entrepreneurs to come back and invest. There is a saying attributed to the father of today’s ruler: his grandfather rode the camel from dune to dune. His father drove the first Mercedes. And yet he knows: his grandchildren will ride camels through the dunes again. What is built on sand ends up in the sand.

Editorial note: The UAE introduced a 9% corporate tax for the first time on 1 Jun 2023 (Decree-Law 47/2022). The DFM Real Estate Index — listed developer equities such as Emaar — lost around 21% in spring 2026 after the outbreak of the US–Iran conflict; physical property prices corrected far more moderately (~4–5%).

TFPut the property problem in a nutshell for a layperson.

PATRONYou should ask yourself: who seriously believes that on an unrecognised island there is real law and real order? It is precisely the lack of recognition that makes it a grey zone — and thus the dreamed-of “independent haven” that is in truth a war zone, economically and physically. Company constructs with accounts can be relocated. But everything physical — property, and all the more one’s centre of life — means playing Russian roulette with your money and your life. And the probability that you lose is close to one hundred percent.

TFYou often point to Cyprus 2013, when 47.5 percent of large deposits at Bank of Cyprus were seized overnight. Why is that the decisive proof for you?

PATRONOne of my mentors taught me: learn history, understand history, live in the present, create the future. Whoever does not know history does not perceive the present and cannot shape the future. Cyprus 2013 is not an isolated case but a pattern. It will return — and next time it will hit above all those who bet on quick gains without doing their homework.

TFWhat makes Georgia different?

PATRONGeorgia has substance, a history, a position of its own. I know the ministerial level, I have met decision-makers who deliberately define themselves neither pro-Europe nor pro-Russia. They say: we are the Switzerland of Eurasia. They talk to everyone — Russians, Europeans, Chinese — and do business with all of them. But they stay true to themselves. That comes from their recent history: the war of 2008 ran through every family. The generation leading today wants to spare their children that. From this follows a deliberately diplomatic, free path — a country that does not want to beg, but to grow in beauty and clarity.

TFThe 1-percent rule — honestly explained, without false hope.

PATRONI would never say “1 percent for everyone” — that would be a lie. The small-business status applies up to GEL 500,000 annual turnover; above that 3 percent. And it does not apply to every activity — certain sectors are excluded. That is why the analysis always comes first: who does what? Where does a relocation even make sense? There is no one-size-fits-all recipe. But there is a workable recipe for everyone.

TFAnd territorial taxation? It’s sold as “completely tax-free”. Is that true?

PATRONNo, and I say so openly. “Completely tax-free” is a lie. Passive foreign income generally remains tax-free. But work I perform physically in Georgia counts as a Georgian source and is taxable — even if the client is abroad and the money never flows to Georgia. It is not at all about paying no taxes. Paying taxes matters to me, because a system everyone benefits from has to be kept running. The only difference is whether that apparatus becomes overreaching — as in the DACH region — or whether it is fair and predictable. I call that fair play: for both sides.

TFThe Estonian model — 15 percent only on distributed profits, zero on reinvestment. What does that mean in practice?

PATRONEvery investment by an entrepreneur creates added value: more company value, more jobs, more revenue. And then he is to be punished for exactly that already at the point of investing? The Estonian model flips it: whoever reinvests pays zero. Tax is due only on what is withdrawn. My grandparents’ generation would turn in their graves at what citizens are expected to bear here today.

TFForeign-agent law, frozen EU accession, Russia-controlled territories — how does that square with a “rule-of-law alternative”?

PATRONThese points are real, and I do not gloss over them. The foreign-agent law is sharply criticised in the West because it obliges foreign-funded organisations — NGOs and media — to register. Georgia has de facto not pursued EU accession on the terms offered. I read this as the sovereign decision of a country that does not want to be co-opted — others see a risk in it. Both are legitimate. Anyone who needs EU legal certainty and Schengen is wrong in Georgia. Anyone seeking a sovereign location that talks to everyone and submits to no one is right.

TFHow would you explain German exit taxation to a master craftsman with a GmbH?

PATRONI will never publicly explain how to get around it. That would help the system close its own gaps — and I won’t do that. What I do say: with clean, forward-looking structure the pain doesn’t even arise. We do that in a legally compliant way, with globally leading firms. But whoever travels the country as a picture of damage has not understood their work. Certain things take time and order: first think, then exchange, then communicate, then act.

TFWhat do people most often get wrong?

PATRONThe reflex to hurry. What I warn everyone against: quickly grabbing the phone and prematurely opening a foreign account somewhere. Highly risky — regardless of whether a single cent ever runs through it, the demonstrable connections alone are a problem. No snap decisions. Everything needs a foundation. Homework first, then the first action. None of us is unique — every problem has already been had by someone, so somewhere the solution already exists too.

TFWhy doesn’t the trap hit the big players?

PATRONThe state reaches for the natural person, the private individual. How shareholdings and companies are structured above that is the decisive question. This is exactly where the big players have positioned themselves so the rules don’t hit them — while the small ones, who don’t know, get caught in full. The system is not equal for everyone. It is just built to look that way. My drive is to give the small entrepreneur the access only corporations used to have.

§ 6 AStG (exit taxation): at ≥ 1% holding in a corporation the treasury assumes, on departure, a fictitious disposal at market value — a gain never realised is taxed. Tightened since 2025.

§ 2 AStG (extended limited tax liability): Germany can reach certain income for up to ten years after departure.

TFWho is Georgia the wrong choice for?

PATRONI turn the question around: who is Germany, Austria, Switzerland the right choice for? It is not about Georgia instead of Germany. It is not about flight. There are paths and structures in which Germany, Austria, Switzerland and Georgia work together — so that in the right case you don’t even have to leave your home country and still have everything in order. You have to see the whole as a whole.

TFYou do draw a line, though — which one?

PATRONWhoever does not carry the principle of Peace, Love & Harmony for more Humanity within them — not only in outward presentation, but inside, in the processes, in how they treat others — we don’t work with. No matter what they pay. Then there is a sincerely meant “all the best” — and a clear no. For me that stands firmer than the amen in church.

TFWhat is the most common illusion people come to you with?

PATRONThat of absolute freedom. As long as we pay taxes, as long as there are rules and statutes, no one is completely free. Many believe a restructuring will suddenly grant them a freedom they never had. I take that illusion from them. But for those who fit us in values, we show paths — and at the end there is a feeling of freedom and a financial availability they never had before.

TFAren’t you a freedom-seller yourself — only with Georgia instead of Dubai?

PATRONThe difference is: I never claim another country is the solution. It is not about Georgia instead of Dubai or Germany instead of somewhere. It is about freedom, independence, self-determination. Everyone has an origin, something they call home. The goal is to be able to shape your life so that you decide freely where you live. You have arrived when you have understood: you may be wherever you want.

TFWhat distinguishes the €111 from an ordinary brochure off the internet?

PATRONNot the information — the depth. It is about leading a free, fully self-determined life in your self-chosen home — with the maximum return from the most precious good you have: your own time. And the return should land where it belongs. Seventy percent or so should stay with you, not the state. Capital is the capacity to act. The capacity to act is freedom. Whoever has no capital has no capacity to act — and thus no freedom.

TFWhat if Georgia scraps its model tomorrow?

PATRONGeorgia itself protects against that. The state has given everyone who founds today a guarantee: the legislation that applies on the founding day remains in force for them for ten years. Whoever signs in June signs under today’s statutes — with ten years of security. That is called commitment. On it you build trust, from it comes stability, from that the capacity to act, from that freedom.

TFWhat is the most uncomfortable truth about your own business?

PATRONI don’t have one. What I encountered as resistance was never a contradiction for me, but a process of learning. Whoever asks gets an honest answer. And if something later does turn out to be a contradiction, I am the first to admit it. But then it was part of the path that brought me to where I stand today.

Is Georgia really “completely tax-free”?

No. “Completely tax-free” is a lie. Georgia taxes territorially: passive foreign income generally remains tax-free. But active work physically performed in Georgia counts as a Georgian source under Article 104 of the Georgian Tax Code and is taxable — even if the client is abroad and the money never flows to Georgia.

What is the 1% tax in Georgia — and who does it not apply to?

The Small Business Status taxes turnover at 1% up to GEL 500,000 annual turnover; above that 3%. It does not apply to every activity — gambling, excisable and licence-bound as well as certain consulting and construction activities are excluded. (Tax Code of Georgia, Art. 79, 82)

What is exit taxation under § 6 AStG?

When a shareholder holding at least 1% of a corporation moves away, the German tax authority assumes a fictitious disposal of the shares at market value — a gain that was never realised is taxed. Tightened since 2025. Added to this is § 2 AStG: Germany can reach certain income for up to ten years after departure.

How secure is Georgia’s tax model in the long run?

The Georgian investment-protection law (Law of Georgia on Promotion and Guarantees of Investment Activity) states that a later act worsening investment conditions does not apply to investments already made for ten years — the investor continues under the previously applicable law.

Isn’t Georgia a rule-of-law risk (foreign-agent law, EU accession)?

These points are real and not glossed over: the internationally criticised “foreign-agent law” of 2024, the de facto stalled EU accession, and the Russia-controlled territories of Abkhazia and South Ossetia. Anyone who needs EU legal certainty and Schengen is wrong in Georgia.