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iGaming: tax, structure, payments and the licence for an operator

Operators, B2B suppliers and affiliates. We cover what comes after the licence and alongside it: where to keep the company and the money, how to pay tax on GGR, how to set up a payment agent, and which accounts will actually open for this profile.

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Curaçao · Cyprus · 2025

A structure for the new Curaçao licence for a B2C operator with three brands

The operator ran through one company on a sub-licence and had to move to a direct licence under the new law (LOK). We separated the roles: the licensee in Curaçao, a payment agent in Cyprus to take deposits, a separate IP company for the brands and domains. We prepared the regulator’s file together with the AML and responsible-gambling policies. The licence was granted, two EMI accounts for the agent were open before launch, and traffic moved across without a pause in player payouts.

Costa Rica · Cyprus · 2024

A group of companies for a B2B game studio: IP in Cyprus, licensing through Costa Rica

A studio sold games both to EU-facing aggregators and to operators in high-risk jurisdictions through a single company — and paid tax where it had no business being taxed. We built a group: a Cypriot company holding the game rights (IP Box regime) and the aggregator contracts, and a Costa Rican company that licenses the software to operators in high-risk jurisdictions where no local certification is required. We agreed transfer prices inside the group and opened accounts for both. The tax burden came down, and each licensing channel got the company that fits it.

Anjouan · Lithuania · 2026

Accounts for an operator after two bank refusals

An operator licensed in Anjouan had been refused twice: the bank could not see who in the structure took the players’ money, and the beneficial owners did not match across the documents. We took the structure apart, added a payment agent, and rewrote the business description and the flow of funds in the language compliance teams read. The third application landed an EMI in Lithuania for operating payments plus a PSP for player deposits. Seven weeks from the first meeting to a working account.

Malta · Ukraine · 2025

A Maltese holding plus operator: fiscal unit, dividends and the founder’s CFC reporting

A Ukrainian founder owned a Maltese operator through a Maltese holding, paid 35% on profit and then waited months for the tax refund. We registered the holding and the operator as a fiscal unit: the group now pays an effective 5% in Malta up front, with no refund mechanism. We mapped the dividend route to the founder and calculated the Ukrainian tax under the double-tax treaty, then prepared the notice of acquiring the shareholding and the first CFC report. The result is a clear annual calendar: what the group pays in Malta, what the founder declares in Ukraine.

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