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TOP-5 of tax and operational burden optimization methods

Introduction: "quality economy" instead of aggressive schemes

Optimization in iGaming is not about gray solutions, but about managing the place of value creation (where people, technologies, licenses and risks are located) and process efficiency. The goal is to reduce the aggregate tax rate and transaction costs without violating the rules (GAAR/BEPS, AML/KYC, advertising norms) in order to improve free cash flow and reduce the cost of capital.


Method 1. Jurisdictional Architecture and Licensing

The idea. Spread functions across companies/countries so that taxes reflect the real "substance" (personnel, decisions, risks), and licenses cover target markets without unnecessary fees.

How to:
  • HoldCo → OpCo → IP/PlatformCo chain: holding for investments and M&A; operating companies for B2C/B2B; separate entity for IP/platform where IP benefits are possible.
  • Substance and PE risk: board, C-level, back office and solutions - in the country where you reflect profits. Avoid "empty" companies.
  • Licenses and fees: choose licenses that allow you to operate in target GEOs with adequate annual fee and clear reporting. Use umbrella/multi-vertical resolutions if necessary.
  • Dividend/royalty/interest taxes: Check for double tax treaties (WHTs) and internal anti-abuse regulations.
  • Pillar Two (min. 15% tax): on a global scale, model the GloBE effect in advance so as not to "eat" the benefits.

Key metrics: effective tax rate (ETR), share of licenses with "supervision without fines," share of revenue from "white" GEO.

Risks/red flags: artificial fragmentation of functions, nominal directors, lack of real employees and solutions at the place of registration.


Method 2. Transfer Pricing (TP) and IP Structure

The idea. Earnings should "follow" functions, assets and risk (FAR). A well-formed IP structure and TP policies reduce ETR and protect against additional charges.

How to:
  • IP/PlatformCo: Keep the rights to code, engines, mathematical models and trademarks where IP modes (patent/innovation boxes) are available and there is a real R&D substance.
  • TP models: royalties (TNMM/CPM), cost-plus for shared-services (2-10% +), profit distribution (Profit Split) for integrated businesses (for example, live-casino + platform).
  • CSA/Cost-Sharing: Co-development agreements - transparently share costs and future benefits.
  • Documentation: master/local file, benchmarking, process and risk maps; with meaningful flows - think APA (preliminary tax agreement).

Key metrics: profit share in the IP center, royalty rate to NNR/NGR, compliance with benchmarks.

Risks/red flags: royalties "out of thin air" without real IP activity, lack of benchmarks and FAR descriptions.


Method 3. VAT/VAT/GST and other indirect taxes

The idea. Proper determination of the location and status of services (digital services, intermediation, B2B/B2C) avoids the VAT and double taxation cascade.

How to:
  • Place of Supply: correctly determine where VAT arises (at the place of customer/contractor/actual use).
  • Reverse charge & VAT groups: use self-assessment mechanisms within the group so as not to "twist" input VAT between related companies.
  • Marketplace/agent vs principal: correctly formalize the role of aggregators/affiliates; this changes VAT duties.
  • Export of services/zero-rating: for confirmed export operations, a rate of 0% is possible (if the conditions are met).
  • Digital registrations (OSS/MOSS/equivalent): simplify reporting in the EU and other regions for B2C digital services.

Key metrics: share of "recoverable" input VAT, penalty risks, accuracy of determining the status of the transaction.

Risks/red flags: errors in the principal-agent chain, lack of evidence of the place of consumption, incorrect application of benefits.


Method 4. Payment circuit and treasury: taxes + OPEX

The idea. Optimize fees, working capital and WHT/taxes by embedding proper payment routing and currency risk management.

How to:
  • PSP/APM orchestration: at least two routes on GEO, auto-steering at approval rate/cost. Reduces MDR/decline/chargeback and increases NGR.
  • Settlement calendar: less often - cheaper than commission, but cash-gap is important; balance with marketing and player payments.
  • Transaction centers: cash-pooling, netting (intra-group netting), centralized FX hedge (NDF/forwards) by major currencies.
  • Withholding taxes: Check WHT for fees/royalties/interest, use double tax treaties and residency certificates.
  • Insurance and reserves: funds for chargeback/fraud, professional liability insurance of a payment intermediary.

Key metrics: approval rate, cashout T-time, blended MDR, FX-slippage, receivables/payables turnover.

Risks/red flags: single PSP, no SoF/AML procedures, "manual" FX with no limits or policies.


Method 5. Operational practices: FinOps, compliance automation, vendor management

The idea. Systematically reduce fixed costs and "hidden taxes" on inefficiencies.

How to:
  • FinOps for the cloud: cost tags, budgets for the environment/product, auto-suspend unused resources, reserved/spot instances, SLO-oriented capacity.
  • Compliance automation: KYC orchestration (tiered checks), RGS triggers with explainable logic, evidence log for audit. Less manual work → fewer mistakes and penalty risks.
  • Vendor consolidation: combine providers (CDN, anti-fraud, monitoring) → volume discounts and fewer integrations.
  • Procurement-playbooks: RFP/RFQ with TCO, SLA/fines, right of unilateral termination with off-boarding PSP/regulatory changes.
  • Release processes: change-freeze under audit/peak periods so as not to catch accidents and fines.

Key metrics: Cost-to-Serve (per active user), Cost of Compliance/Net Revenue,% KYC auto-pass, uptime/SLA vs cost.

Risks/red flags: "zoo" of vendors, lack of SLO/SLA, manual KYC processes without quality control samples.


Quick example of economic effect (conditional mid-size, year)

Before optimization:
  • ETR 24%, blended MDR 2. 9%, approval 83%, cloud $1. 2M/год, Cost of Compliance = 7. 5% Net Rev.
After (12 months):
  • Jurisdictional realignment + TP/IP: ETR 19% (− 5 pp).
  • PSP orchestration: approval 88%, MDR 2. 4% (−0. 5 pp).
  • FinOps/vendor-consolidation: cloud − 18% (up to $984k).
  • Auto-KYC and evidence-log: CoC 6. 1% (−1. 4 pp), penalty risks ↓.

Total effect: + 2. 8–4. 1 p.p. to EBITDA margin and ~ $1. 5–2. 3 million annual savings on revenue of $60-70 million NGR (estimated).


Check sheets

Governance & tax base

  • Function/Risk Map (FAR) and Substance Compliance
  • TP policy, benchmarks, master/local file
  • IP rights and R & D/development documentation
  • Pillar Two/ETR Model and Robustness Test

VAT/Indirect

  • Correct location, contractual roles (principal/agent)
  • VAT groups/reverse charge, export confirmations
  • OSS/MOSS/analog for digital services

Payments/treasury

  • GEO PSP/APM ≥2, auto-routing, approval reports
  • Settlement calendar, cash-pooling/netting
  • FX policies and limits, residency certificates for WHT

Operations

  • FinOps dashboard, cost tags, reserve/spot policy
  • KYC/RGS orchestration and evidence repository
  • Vendor consolidation and RFP archive, SLAs/penalties

Common mistakes

1. The race for the "minimum rate" without substance → the risk of additional charges and fines.

2. Royalties/services between related parties without benchmarks and FAR descriptions.

3. Incorrect chain role definition (principal/agent) for VAT.

4. The single PSP and manual FX → high MDR/spreads and losses.

5. Lack of FinOps and compliance automation → hidden taxes on inefficiencies.


Tax and operational load optimization is a business architecture plus process discipline. Put functions where you really create value; fix it in TPs and documents; control VAT and payments; standardize compliance and cloud spending. This approach is legal, stable and converts into higher EBITDA and free cash flow, which means - into higher capitalization and better financing conditions.

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