Where to Incorporate an iGaming Company: Tax, Banking, Substance and Staff
Where to base an iGaming operator, B2B company or holding company: license rules, tax on profit and dividends, treaties, banking, substance and staff costs.
David SisvadzeCEO, GamblingLicense.ge
Where to incorporate an iGaming company is usually three questions, not one. The license decides where the operating company sits, tax treaties decide where the holding company can sit, and staff costs and talent decide where the development team works. This guide compares Georgia, Malta, the Isle of Man, Curaçao, Estonia, the UAE and Cyprus on the points operators actually decide on.
What Decides Where an iGaming Company Should Sit
Fee tables rank licenses by price, but a base is chosen on what it costs to run and whether banks and suppliers will work with it. These are the points that decide it:
- License fit. Whether the regulator you need licenses only local companies, and what presence it expects.
- Tax on profit and dividends. Gaming duty, company profit tax and tax on dividends paid to the owners, taken together.
- Treaties. Whether dividends can reach the parent company without tax withheld on the way.
- Banking. Whether a bank and a card acquirer in that country will take a gambling company.
- Substance. What the country expects on the ground: directors, an office, servers, staff.
- Staff. What people cost there and whether the skills exist locally.
The License Usually Fixes the Operating Company
The company that holds the gambling license has the least freedom, because most regulators grant licenses only to companies formed under their own law. The table shows what each regime asks of the license holder.
| License | License holder must be | Presence required |
|---|---|---|
| Georgia, international permits | A company registered in Georgia | Management address and server infrastructure in Georgia |
| Curaçao | A Curaçao company with its registered office there | Local director; critical data on a Tier IV server in Curaçao; wider substance rule from 1 April 2027 |
| Malta | An entity established in the European Economic Area | Key function holders approved by the MGA; €100,000 capital for casino or betting |
| Isle of Man | A Manx company | Two resident directors, servers on the island, player funds in a Manx bank |
| Estonia | A company registered in Estonia or the EU, with gambling as its sole activity | Connection to the tax board's control systems; €1,000,000 capital for casino |
| Anjouan | No local company rule published | Key person and compliance officer |
| Kahnawake | No local company rule found | Hosting at the licensed facility in Kahnawà:ke |
The other parts of a group have more choice. A B2B company that develops games or a platform can sit where the developers are, subject to supplier licensing in each market it serves. A holding company can sit wherever the treaty network, its own tax and its owners' needs point. Anjouan and Kahnawake leave even the operating company's location open, which means the profit tax and the banking are those of wherever it is incorporated.
Tax on Profit and Dividends
The headline rates below are statutory, before rulings, refunds that need a claim, or group relief. Gaming duty and profit tax work on different bases, so they cannot simply be added up.
| Country | Company profit tax | Dividends to a foreign parent | Gaming charge |
|---|---|---|---|
| Georgia, international permit holder | None on retained profit; the gambling tax replaces it | 5% withheld unless a treaty lowers it | 5% of foreign-player GGR plus 1% monitoring fee |
| Georgia, other companies | 15% when profit is distributed, 0% while retained | 5% withheld unless a treaty lowers it | Not applicable |
| Malta | 35% headline, 0%–10% effective after shareholder refunds, or an optional 15% final rate since September 2025 | No withholding to non-residents | Compliance contribution; 5% tax on players in Malta |
| Isle of Man | 0% standard rate | No withholding | Duty of 0.1%–1.5% of yield by band |
| Curaçao | 15% up to about €250,800 of profit, 22% above, on Curaçao-source income | No withholding | None in the fee schedule |
| Estonia | 22% of the gross amount when profit is distributed, 0% while retained | Charged through the distribution tax | 5.5% of bets less prizes |
| UAE | 0% up to AED 375,000 of taxable income, 9% above | Withholding tax at 0% | Holding company role only in this comparison |
The UAE rate comes from Cabinet Decision No. 116 of 2022, and a Qualifying Free Zone Person pays 0% on qualifying income. Georgia's figures are in Articles 97, 98 and 130 of the Tax Code: the gambling tax is charged on gross gaming revenue every month, profit from that activity is treated as distributed first, and dividends out of it carry 5% withholding, because the dividend exemption covers only profit taxed at the 20% domestic rate.
A tax on revenue and a tax on profit favour different businesses. Georgia's 5% is owed in a loss-making month, while Curaçao's and Malta's profit taxes are not, and at high margins a profit tax takes the larger share, so iGaming tax by jurisdiction has to be modelled on your own margin, not compared on headline rates.
Treaties and the Holding Company
Georgia has 58 double tax treaties in force, according to the Ministry of Finance, against 4 for Curaçao and about 10 full tax agreements for the Isle of Man. Several of Georgia's treaties set 0% on dividends, among them those with Malta, Cyprus, the UAE, Estonia, Qatar, Bahrain, Singapore, San Marino, Liechtenstein and Slovakia, and others, including the UK, the Netherlands, Germany, Ireland, Luxembourg and France, have a 0% tier for holdings above a threshold.
Planning that route is part of gambling tax advice in Georgia, because the treaty rate, the size and length of the holding and the parent country's own tax on the dividend all change what reaches the owners.
Banking Follows the License and the Company
Card acquiring is where the choice of base shows up first. Under rule 1.5.1.1 of the Visa Core Rules, an acquirer may normally take transactions only from merchants in its own country, and for online payments the merchant's location is its principal place of business. Rule 5.8.18.1 adds that an online gambling merchant must hold a valid license for its site. A license, a company and an acquirer in one country is the default set-up those rules describe.
A Georgian permit fits that structure, because the license, the company's management and its servers are all in Georgia. Georgian-licensed operators already take Visa, Mastercard and American Express deposits through channels at TBC Bank, Bank of Georgia and Liberty Bank, and Georgia's 2021 payment ban targets only payments by Georgian residents to foreign gambling companies. No Georgian bank has yet said publicly that it acquires for international permit holders, so the bank account for a gambling company is a conversation to open in the first week, not after the permit.
The other end of the range is Anjouan. On 8 December 2025 the Central Bank of the Comoros said the Anjouan authority is not recognised in the Union of the Comoros, that no online betting or gaming license has been issued there, and warned against dealing with entities operating under its licenses.
Substance: What Each Country Expects on the Ground
Paper companies are a weak base for a gambling business. Georgia's application gives the actual address from which the games are managed and the address of the server infrastructure, both in Georgia. Curaçao has deferred its wider local-substance requirement to 1 April 2027 but already wants a local director and a server on the island. The Isle of Man rejects brass-plate applications and asks for two resident directors and a resident designated official or a locally based operations manager.
Substance also decides tax residence. The UAE's corporate tax applies to companies incorporated or effectively managed and controlled in the UAE, according to its Ministry of Finance, and most tax systems look at where a company is really run. A holding company managed day to day from somewhere else can end up taxed there.
Staff Cost and Talent
Average gross monthly earnings in Georgia were about €821 in the second quarter of 2026, and about €1,513 in information and communication, according to Geostat. The industry is already there: Evolution's 2025 annual report names Tbilisi as its largest hub, with 4,813 staff in Georgia at the end of 2025, and Random Systems Georgia's permit list for 2019 to 2023 shows supply permits held by Entain Georgia, Evolution Georgia, Spribe Georgia and Smartsoft among 37 game suppliers.
A group's development team can sit in a separate Georgian company with International Company status for iGaming studios, which applies to software and IT services delivered under service contracts. The status needs 2 years' experience, core income-generating work done in Georgia, adequate qualified staff and adequate operating costs, and organizing gambling is not a permitted activity, so the permit-holding operator cannot use it.
When Georgia Is the Right Base, and When It Is Not
A Georgian permit holder keeps the license, the company, its servers and its management address in one country, and most of the work of forming an iGaming company in Georgia is arranging those four before the filing. It suits:
- Operators who want a national-law license. The permits come from Law No. 1822 of June 2026 and are issued by the Revenue Service of the Ministry of Finance.
- High-margin casinos and sportsbooks. Tax is a fixed 5% share of gross gaming revenue, so the profit above it carries no corporate tax while it stays in the business.
- Groups with a parent in a 0% treaty country. Dividends can leave Georgia without the 5% withholding.
- Groups that want operations and development in one city. Tbilisi has the staff, and a separate B2B company may qualify for International Company status.
It is the wrong base for:
- Crypto-first casinos, because Georgian law offers no lawful crypto deposit route for international permit holders today.
- Low-margin or early loss-making books at small scale, because the permit fees are fixed and the gambling tax is owed in loss months.
- Operators who want Georgian players, who are barred from the international permits.
On total tax Georgia is not the cheapest of these. On statutory rates, an online casino with €1,000,000 of gross gaming revenue and €300,000 of profit pays more in Georgia than in Curaçao or the Isle of Man, and Georgia's revenue tax undercuts Curaçao's profit tax only for high-margin operators at scale, so Georgia against Curaçao, Malta and the Isle of Man is a comparison of standing, banking structure, term and staff as much as of tax.
Where to Incorporate an iGaming Company FAQ
What is the best country to incorporate an iGaming company?
The one your license requires for the operating company, with the holding and development companies placed by treaties, tax and staff. Each country leads on something different: the Isle of Man on company tax, Georgia on staff costs and its 58 treaties, Curaçao on an indefinite license term.
Do I need a local company to hold a gambling license?
Usually, yes. Georgia, Curaçao and the Isle of Man license only local companies, Malta asks for a company in the European Economic Area and Estonia one in Estonia or the EU. Anjouan and Kahnawake publish no local company rule.
Can the holding company be in another country?
Yes. A Georgian operator's dividends to a foreign parent carry 5% withholding unless a treaty lowers it, and Georgia's treaties with Malta, Cyprus, the UAE and Estonia, among others, set 0%. The parent needs real management where it is incorporated.
Which country has the lowest tax for an iGaming company?
Among these, the Isle of Man, with a 0% standard company rate and gambling duty from 0.1% to 1.5% of yield. Georgia charges 5% of gross gaming revenue plus a 1% monitoring fee instead of profit tax, which is lower than a profit tax only for high-margin operators.
Does Georgia tax dividends paid abroad?
Yes, at 5% under Article 130 of the Tax Code, unless a tax treaty lowers the rate. Dividends out of profit from foreign players are not exempt; the exemption covers only profit taxed at the 20% domestic rate.
Do I need staff in the country where the company is incorporated?
For most licenses, yes, in some form. Georgia asks for a management address and servers in the country, the Isle of Man for resident directors, and Curaçao for a local director now and wider substance from April 2027.