What is the Cyprus company + foreign licence structure?
It is a two-part structure: a Cyprus company acts as the EU corporate, tax and intellectual-property base, while the actual gaming licence is held in a suitable foreign jurisdiction such as Malta, Curaçao, the Isle of Man or Anjouan. Cyprus itself does not issue online casino licences, so the licence always sits abroad — but the company that owns the business, the software IP and the profits is Cypriot.
This pairing gives operators the credibility and tax efficiency of an EU holding structure together with a gaming licence chosen for their product and target markets. You can compare the licence options in our jurisdiction comparison.
Why base the company in Cyprus?
Cyprus is the corporate and tax base — not the licence. As an EU member it offers a 15% headline corporate tax (from 2026), an effective rate of roughly 3% on income from qualifying software IP under the IP Box, and a network of 65+ double-tax treaties.
- 15% corporate tax — among the lowest headline rates in the EU.
- ~3% effective on qualifying software IP via the IP Box (80% deduction). See the IP Box & tax guide.
- EU member & eurozone — a recognised entity for banking, PSPs and B2B partners.
- 0% withholding tax on outbound dividends, interest and royalties to non-residents (rights used outside Cyprus).
- 65+ tax treaties and access to EU Parent-Subsidiary and Interest & Royalties Directives.
Can a Cyprus company hold the gaming licence?
Generally no. The stricter regulators require the licensee to be incorporated and substanced locally, so a separate operating company is set up in the licence jurisdiction. The Cyprus company sits above it as the holding and IP company.
| Licence jurisdiction | Who holds the licence |
|---|---|
| Malta (MGA) | EU/EEA company (in practice Maltese) |
| Isle of Man (GSC) | Isle of Man company |
| Gibraltar | Gibraltar company |
| Curaçao (LOK / CGA) | Curaçao company + local managing director |
| Kahnawake (KGC) | Client Provider Authorization (CPA) |
| Tobique (Canada FN) | No local company required |
| Anjouan (Comoros) | Registered address + local representative |
How the structure works
Three roles sit in the structure, and value flows between them at arm’s length:
- Cyprus HoldCo — owns the shares of the licensed operating company; collects dividends with no Cyprus tax on incoming dividends (participation exemption).
- Cyprus IP-Co — owns the qualifying platform and game software; licenses it to the operating company for royalties taxed at roughly 3%.
- Licensed OpCo — the local entity that holds the licence, faces players, books gaming revenue and pays the local gaming tax or duty.
Revenue books in the operating company; royalties flow to the Cyprus IP company (deductible at the OpCo); intercompany service fees are charged at arm’s length; and dividends flow up to the Cyprus holding company and onward to the owners. The full diagram is on the homepage structure section.