Cyprus iGaming Structuring 2026: EU Base, 15% Corporate Tax and Bankable Group Planning

Cyprus iGaming Structuring 2026: EU Base, 15% Corporate Tax and Bankable Group Planning

Introductory summary

The global online gambling market is now measured in the tens of billions and is forecast to expand substantially through the decade, with one widely cited estimate placing the market at USD 78.66 billion in 2024 and projecting USD 153.57 billion by 2030. In a sector of this scale, jurisdiction choice is not simply an incorporation decision. It is a strategic foundation for banking and payments access, diligence readiness, tax defensibility, and stakeholder confidence.

Cyprus continues to feature prominently in iGaming group structuring because it combines EU membership and euro area participation with a modern corporate and tax framework. Cyprus has been an EU Member State since 1 May 2004 and has been in the euro area since 1 January 2008. From 2026, Cyprus’ corporate income tax rate increased from 12.5% to 15%, reinforcing its positioning within contemporary international standards while remaining competitive by EU benchmarks.

Chambers & Co advises iGaming groups using a bankability-first approach that treats structure as something to be evidenced under scrutiny, not merely described on a slide. The firm’s iGaming experience is informed by Richard Chambers’ long-standing involvement in the sector since 1998, including direct exposure to the operational realities that drive regulatory, payments and investor outcomes.

1. The iGaming scale effect: why “good enough” structures fail as groups grow

In early-stage iGaming, many groups operate with practical compromises: simplified governance, evolving contracting, and payment workflows that are operationally effective but not always documentary-perfect. At low volumes, these gaps can remain dormant.

At scale, they become expensive.

The iGaming business model is payments-intensive, cross-border by default, and increasingly institution-facing. Growth typically brings:

  • heightened onboarding scrutiny from banks, EMIs and PSPs

  • more intrusive transaction monitoring and reserve practices

  • investor diligence that expects corporate coherence and evidence of control

  • tax defensibility questions focused on where value is created and where decisions are made

In a multi-billion industry environment, counterparties do not assess only ambition and revenue. They assess controllability and risk. In practice, this means the structure must withstand third-party scrutiny: not only legality, but credibility.

In iGaming, “structure” is not the company chart. It is the documentary truth of how the group operates, how funds move, who controls risk, and where decisions are made.

2. Why Cyprus remains a serious EU platform for iGaming groups

Cyprus works well for sophisticated iGaming groups because it can credibly sit at the centre of European operations and governance, provided the implementation is disciplined.

Two features are foundational:

  • EU membership since 1 May 2004

  • euro area membership since 1 January 2008

For iGaming, these anchors matter because many of the most important stakeholders (banks, EMIs, card schemes, regulated PSPs, institutional investors, professional directors, auditors) often prefer jurisdictions that fit established compliance and governance expectations.

Cyprus also benefits from deep professional services infrastructure. In practice, this supports:

  • real management and control arrangements, where required

  • board governance and committee oversight consistent with institutional expectations

  • robust accounting and audit capability for group reporting and diligence

  • practical support for onboarding files, licensing support functions, and compliance programmes

Chambers & Co’s approach is to treat Cyprus as a platform rather than a label. A Cyprus company can be formed quickly. A Cyprus base becomes valuable when it is built to be credible under examination.

3. The 2026 tax baseline: 15% corporate income tax and the credibility dimension

From 2026 profits onwards, Cyprus’ corporate income tax increased to 15%.

For iGaming groups, the relevance is not limited to headline rate comparison. In a sector where banking and investor acceptance is often as important as pure tax arithmetic, a modernised and internationally legible tax position can support the overall jurisdiction narrative. That is particularly true where a group is building for institutional scale, potential M&A, or external capital.

A recurring theme in sophisticated iGaming planning is that friction costs dominate. Delayed onboarding, restrictive reserves, adverse monitoring, and repeated remediation requests can be more expensive in practice than modest differences in headline corporate tax rate.

This is why Chambers & Co tends to frame tax as one component of an integrated plan: bankability, substance, defensibility and scalability.

4. Defensive measures from 2026: why clean footprints matter more than ever

Cyprus has introduced defensive measures targeting low-tax jurisdictions and certain blacklisted jurisdictions. Effective 1 January 2026:

  • dividends paid to associated companies in low-tax jurisdictions become subject to 17% withholding tax

  • interest and royalties paid to associated companies in low-tax jurisdictions are not deductible for corporate tax purposes

For iGaming groups, these measures have practical consequences because the sector historically included offshore elements in holding, IP, and treasury chains. The direction is clear: structures relying on low-tax associated counterparties can attract both tax friction and counterparty resistance.

In payments onboarding, jurisdiction complexity is rarely neutral. Even where legal, it can increase perceived risk and produce more intrusive monitoring, reserve requirements, or adverse decisions. The post-2026 landscape rewards groups that can present a clean, coherent footprint that aligns with modern compliance expectations.

5. Cyprus tools that sophisticated iGaming groups still use, when properly evidenced

Cyprus is rarely selected solely for one tax feature. It is selected because it can combine several credible tools into a coherent structure.

5.1 Notional Interest Deduction: equity-funded growth with a recognised framework

The Cyprus Ministry of Finance describes the Notional Interest Deduction (NID) as an annual deduction on new equity, calculated using an interest rate methodology, and notes that the NID cannot exceed 80% of the taxable profit generated by the activities financed by the new equity.

In iGaming groups, NID can be relevant where the business is being capitalised properly and where equity-funded growth is part of a credible treasury and governance narrative. The key is coherence and evidence: new equity, deployed into real activities, generating real taxable profits in a way that can be documented.

5.2 IP Box: powerful for qualifying tech models, but evidential by design

Many modern iGaming groups are, in substance, technology businesses: platform operators, game studios, risk and pricing engine builders, and data-driven marketing organisations. Cyprus’ IP Box regime can be relevant where the group has qualifying IP and can evidence the nexus between qualifying expenditure and qualifying income.

Cyprus’ IP Box framework provides for an 80% deduction on qualifying profits derived from qualifying intellectual property, subject to the applicable eligibility and nexus conditions.

The practical reality is that IP Box is not a superficial election. It is an evidential regime. Serious groups prepare for this by ensuring that:

  • chain of title is clean and current

  • developer and contractor IP assignments are properly executed

  • intra-group licensing is coherent and priced in a supportable way

  • R&D activity and qualifying expenditure can be evidenced and tracked

  • governance oversight exists, including board-level understanding and sign-off

5.3 Non-dom and tax residency planning: supporting real decision-making in Cyprus

Cyprus has a well-established “non-domiciled” framework for Special Defence Contribution (SDC). Individuals who are not domiciled in Cyprus for SDC purposes are exempt from SDC, and dividends and most types of interest income received by such individuals are generally exempt from taxation in Cyprus.

Cyprus also provides a 60-day tax residency route, subject to conditions, which can support internationally mobile founders and executives where the factual criteria are met.

For iGaming groups, these tools matter because credible Cyprus structures often require credible Cyprus-based decision-making. Chambers & Co’s experience is that substance is not a separate compliance exercise. It is a business discipline that supports outcomes with banks, PSPs, and investors.

6. Bankability-first structuring: the standard that matters in iGaming

In iGaming, the most consequential stakeholder is often the one with the power to slow the business down: a bank, EMI, PSP, card programme partner, or correspondent channel. This is why bankability-first structuring is often the difference between scale and friction.

In practice, counterparties tend to test:

  • clarity of beneficial ownership and control

  • flow-of-funds logic and documentary alignment (contracts, bank statements, ledgers)

  • delegated authority, signing mandates, and governance controls

  • AML programme maturity and escalation pathways

  • jurisdictional exposure, including low-tax associated entity flows

Chambers & Co’s planning approach typically treats these as design inputs, not post-factum remediation tasks.

This is also where Richard Chambers’ experience since 1998 informs the firm’s methodology. The firm does not treat iGaming as a theoretical legal category. It treats it as a high-velocity, payments-dependent sector where the operational reality drives what is acceptable in practice.

The question is not whether a structure can be drafted. The question is whether it can be explained, evidenced, and defended when scrutiny increases.

7. Cyprus structuring patterns that sophisticated iGaming groups tend to prefer

There is no single “correct” structure. However, sophisticated groups commonly converge on models that minimise friction and maximise defendability.

In broad terms, Cyprus is used effectively as:

  • a governance and holding hub, supporting investment readiness

  • a management and control base, aligned with substance evidence

  • a treasury hub, where cash management and financing are coherent and documented

  • a technology and IP centre, where development activity and nexus evidence exists

The common thread is consistency between narrative and evidence. If Cyprus is presented as the centre of governance, then board practice, signatories, decision trails, and management activity should support that position.

8. Concluding practical section: the questions iGaming groups should answer before they scale

The following questions are framed around what banks, PSPs, investors and auditors typically test.

8.1 What is the role of Cyprus in the group?

Is Cyprus a holding hub, a management base, a treasury centre, a technology and IP centre, or a combination? The structure should not be ambiguous.

8.2 Can the group evidence management and control in Cyprus?

Decision-making should be real and provable. Minutes, mandates, approvals, and operational behaviour should align.

8.3 Is the flow of funds simple, coherent, and contractually aligned?

If onboarding asks for a flow-of-funds narrative, can the group provide one that matches contracts, ledger postings, and bank movements without inconsistency?

8.4 Does the corporate map match the risk map?

Where do operational risks sit? Where do valuable assets sit? Are risks unnecessarily commingled with high-value IP or cash pools?

8.5 Is the structure designed for the 2026 environment?

Are there payments to associated companies in low-tax jurisdictions that trigger 17% withholding on dividends or non-deductibility for interest and royalties from 1 January 2026? If yes, is there a defensible restructuring plan?

8.6 If NID is relevant, is the equity story coherent and evidential?

Is the equity new, deployed into real activity, and traceable to profit generation, within the 80% cap framework described by the Ministry of Finance?

8.7 If IP Box is contemplated, does the group have the evidential backbone?

Is chain-of-title clean, development properly documented, and the nexus position supportable?

8.8 Is the group prepared for payments and investor scrutiny?

Do policies, governance, and documentation exist at the standard that counterparties will expect for a fast-scaling iGaming group?

Closing perspective

Cyprus remains a credible EU platform for iGaming groups because it combines EU membership and euro area participation with a modern corporate and tax framework. The 15% corporate income tax baseline from 2026 and the introduction of defensive measures reinforce the direction of travel: sophisticated groups succeed where the structure is defensible, bankable, and evidenced.

Chambers & Co advises iGaming groups with this reality in mind. The firm’s approach is shaped by practical sector experience, including Richard Chambers’ involvement in iGaming since 1998, and a consistent focus on what holds under scrutiny as the business grows.