Why Curacao and Malta are changing iGaming's tax system

The main trend of 2025 for "traditional" iGaming jurisdictions is rapprochement with global tax and regulatory standards. This is not cosmetics: due to the new rules, the tax base, access to payment rails, the cost of compliance and the final margin are changing.

1) Global drivers of change

OECD Pillar Two: the introduction of a global minimum effective tax of 15% for international groups with revenues> €750 million. Jurisdictions adapt corporate rules so as not to lose the tax base and the status of a "reliable" site.

Pressure on "gray" schemes and the requirement of transparency: without this, banks and PSPs cut apps, and regulators of recipient countries strengthen supervision.

2) What happens in Curaçao: LOK instead of "sub-licences"

LOK entered into force (National Ordinance on Games of Chance): the master/sublicense model leaves, a new B2C/B2B licensing system is launched under the supervision of the Curaçao Gaming Authority (CGA).

Transition period: extension of temporary (provisional/Green Seal) permits until December 24, 2025 and mandatory reclassification of licenses under LOK (including the completion of "orange" certificates).

How it hits the operator's economy

The taxation base and reporting are getting closer to the "white" markets, regulatory arbitration is leaving "through the sub." Formally, LOK is about regulation, but fiscal discipline and SupTech supervision pull above Compliance-OPEX and better access to PSP (above Approval Rate → more Handle with the same marketing). Confirmed status reduces the risk of locks and chargebacks - this is a plus to LTV.

3) What happens in Malta: spot gaming tax + "minimum 15%" at CIT level

The gaming tax on remote services in Malta is 5% of the gaming-revenue from players located in Malta (that is, a point, not a global turnover fee).

Corporate level: Malta synchronizes with Pillar Two through mechanisms that allow you to apply effective 15% to large MNEs (including local "top-up" according to the new FITWI/MTT rules). This changes the CIT contour for large groups without directly affecting the gaming-tax itself.

In parallel, Malta in 2023 adopted Bill 55 (the legal "wall" against the execution of some foreign decisions regarding MGA operators) - this is about legal protection, not about tax, but important for assessing risks.

Economic effect for the operator

For the average operator (outside the perimeter of Pillar Two), the structure of the gaming tax does not change; more importantly, MGA status increases PSP confidence and reduces Payment Cost/Chargeback Rate.

For a large group (Pillar Two threshold): the corporate tax burden is growing to 15% ETR, which should be included in Net/GGR and the ROI estimate by jurisdiction.

4) "Tax" vs "margin": why regulatory purge still pays off

• + 5 p.p. Approval Rate of deposits (thanks to "white" rails) = + 3-8% to GGR with constant marketing.
• Below Payment Cost% Handle and less Chargeback/Refund Rate → NGR and Retention are growing.
• Transparency (PF artifacts, readable rules) opens up "strict" procurement channels - cheaper than CAC, longer than LTV.

5) Mini P&L: How regime change is reflected in numbers

Let GGR = $2.0 million; 15% GGR bonuses; content 12% GGR; payments of 1.5% GGR; 2% GGR jackpots; OPEX $0.5M

Old "gray" mode: gaming-tax is minimal, but Approval Rate below → Handle is cut; Payment Cost is higher by 0.5 percentage points; Chargeback above.

New "white" mode (LOK/MGA-vector): gaming-tax/ ↑ fees, Compliance-OPEX ↑, but Approval Rate ↑, Payment Cost ↓, ↓ complaints.

In the "mixed" effect, Net/GGR often grows by 2-5 percentage points if payments and retention are really pulled up (and this is a typical outcome when switching to "white" rails).

6) What to put in the model for 2025-2026

1. Curaçao (LOK): re-registration plan (B2C/B2B), provider audit, contract update, Compliance-OPEX budget and reporting; keep track of CGA deadlines (rollovers and deadlines).

2. Malta (MGA): Confirm if you fall under Pillar Two; Rebuild the CIT model and transfer pricing gaming-tax 5% on Maltese players - no surprises, but take into account VAT withdrawals and non-refundable input VAT for a number of services.

3. Payments: compare pre/post migration PSP matrix; target - Approval ≥90% for local methods and p95 Time-to-Payout <4 h (VIP - minutes).

4. Marketing: Prepare white creatives/diskilamers; count iLTV rather than the entire cohort LTV.

5. PF transparency and RG: bring out the "honesty panel" and limits in UI - this speeds up moderation and reduces complaints.

7) Frequent errors

Compare nominal tax only, ignoring base (GGR/NGR), payments and compliance.

Postpone migration under LOK - risk falling under CGA deadlines and getting payment gaps.

Do not take Pillar Two into account in the holding model - a surprise arrives "top-up" up to 15% and breaks Net/GGR.

8) CFO/COO checklist

• Checked which tax base applies (GGR/NGR) and how bonuses are counted.
• Rated Pillar Two (threshold €750 million, math ETR 15%).
• Measured Approval Rate/Payment Cost/Chargeback before and after the mode change.
• Laid down Compliance-OPEX (audits, reporting, SupTech).
• Renewed contracts with content providers under new LOK/MGA licenses.

Curaçao and Malta synchronize with the world: Curaçao closes the era of sub-licenses and introduces LOK + CGA, and Malta retains a predictable 5% gaming-tax and raises the bar for corporate efficiency to 15% ETR for large groups. This increases compliance costs, but improves the funnel of money: white payments, quick payments, access to media, fewer returns and higher trust. For the operator, the conclusion is simple: count not the "rate," but Net/GGR, taking into account payments, bonuses and Pillar Two - and then the "tax reform" turns from a threat into a lever of predictable profit.