georgian tax authorities want her to pay money back from tax exception, because of missing substance.
They say its necessary to have substance (visiting herself or hiring staff) to run the 0% tax - company was founded before pandemic,
visiting the country was not possible a long period of time.
What are your opinions on
1. fighting through court - any recommendation i could give her for legal help
2. just leaving the amount there and never visit georgia again (the amount increases per month i guess)
How big is the tax bill? Court battles can be expensive, so it's probably cheaper to pay.
The risks associated with dodging the tax bill depends on the size of it and how affected the person is by Georgian political influence and whether the tax bill can be collected through debt collection. It's possible the debt will just accrue and after many years be struck off. The problem is if you ever want to return to Georgia.
Have you discussed with the tax authority and try to work something out? If you explain you intend to establish a substance now and couldn't earlier due to COVID-19, they might be understanding. Go through a local attorney.