BLK Advisory Services · The 3% Advantage
97%
Keep the licence Malta gave you. Move the technology you built.
Your MGA licence, your operation and your players stay exactly where they are. We build a Cyprus TechCo that owns and licenses your platform IP at near 3% effective on qualifying IP profit, so 97% of it stays in the business. One measured step, with your operation untouched.
Regulated Cyprus tax advisors in our partner network issue a formal opinion for every tax position. BLK builds and runs the structure end to end. Figures reflect Cyprus law in force from 1 Jan 2026.
The Malta arithmetic
The refund system worked. It also costs you every year.
We put your technology where it’s treated best and leave your Malta operation exactly where it is.
- 35%
- paid upfront under the refund system and reclaimed later. A permanent cash-flow drag.
- Months
- of refund-cycle mechanics and structuring overhead on every distribution
- ~2%
- the delta on qualifying tech profit: the refund route runs ~5% effective, the Cyprus IP Box ~3%
- Haircut
- at exit, when buyers discount earnings that are complex to diligence
Why now
The 2026 reform quietly confirmed it.
Cyprus raised its corporate rate to 15% and kept the IP Box. A builder who qualifies still pays 3%. One call tells you whether yours does.
- 3%
- effective tax on qualifying IP profit
- 0%
- withholding tax on dividends leaving Cyprus
- 17yr
- personal regime for relocating founders
- 8–12 weeks
- from first call to a running structure
Headline figures under the regime, as applied to qualifying structures. A formal opinion quantifies what applies to yours, case by case.
This is not for everyone.
The regime rewards genuine builders. Brands and trademarks don’t qualify; your code does.
Copyrighted software can qualify.
Platform code, engines, trading bridges, algorithms, models and proprietary tooling. Brands, trademarks and other marketing IP are excluded.
It earns qualifying income.
The IP has to contribute to profit. That includes licence and royalty income, and qualifying income embedded in the products and services you sell.
Who built it matters.
The benefit depends on the R&D behind the IP and who paid for it. Acquired IP and related-party outsourcing reduce the qualifying share. Your engineering team does not automatically have to move: developers you employ, or can relocate and hire. We establish the position before designing the operating model.
One call tells you whether yours qualifies.
The number that matters for Malta operators
On every €1M of qualifying tech profit, moved from the Malta refund route to the Cyprus IP Box:
~€20,000
kept in the business, plus you stop waiting on the refund cycle.
~€50,000 a year at the refund route’s ~5%. ~€30,000 under the IP Box.
Illustrative. A regulated Cyprus tax advisor quantifies your number in a formal opinion, including the one-off Maltese cost of moving the IP.
A step, not an upheaval
What stays. What moves.
We add a technology layer beside your gaming operation. The Cyprus TechCo owns and develops the platform IP and licenses it to your operating entities at arm’s length.
Stays in Malta
- Your MGA licence and regulatory standing
- Your operating entities, brands and player relationships
- Your commercial team and day-to-day operations
- Your PSP and affiliate relationships
Moves to Cyprus
- Ownership of the platform IP, held by a real TechCo
- Qualifying development activity. We build the team, office and substance.
- Royalty and platform-fee income from licensing your own tech
- Near 3% effective on qualifying IP profit, 0% withholding on dividends out to non-residents
The first call maps how this applies to your group.
How it works
From first call to a running structure.
An indicative 8–12 week path. Your MGA-licensed entities keep operating throughout.
First call & KYC
One call and a short document list. Then a straight answer on fit.
Independent tax opinion
Regulated Cyprus advisors put the structure and your number on paper, mapped against your Malta setup.
TechCo & IP assignment
We establish your TechCo, banking and the licence back to your Malta entities, with the Maltese cost of the move priced up front.
Substance build
An office, staff on payroll and board control on the island.
Run & report
We run your books, payments and compliance under one roof.
Four licences,held inside the group
Every part of the structure runs on a licence held inside the group.
Company services
Licensed corporate service provider: incorporation, directorship, substance.
Bookkeeping
Books, payroll, VAT and audit-ready files through our accounting company.
Banking & EMI
IBANs, multi-currency accounts and payment operations via our licensed EMI.
Crypto on/off-ramp
Regulated fiat-to-crypto conversion through our licensed exchange.
The opinions, nexus modelling and tax reporting come from regulated Cyprus advisors. We do not write them and we do not sign them.
Straight talk
Said plainly, before you ask.
A qualified tax advisor designs the structure. We build it, then run it: set-up, substance, books, banking and rails.
- Every tax position comes from a regulated advisor.Regulated Cyprus partners issue the opinions, rulings and audits. We build and run the structure they design, end to end.
- Substance means people, not paperwork.The regime wants development done where the company is, staff who actually work there, and intra-group pricing set at arm’s length. You bring the technical leadership; we handle payroll, contracts and the office. Your tax advisors write the benchmarking file, and we supply the data behind it.
- Your MGA licence stays.The MGA licence is an asset. We add a technology layer beside it and your licence stays exactly where it is.
Questions
Asked and answered.
What is the Cyprus IP Box?
A Cyprus tax regime under which 80% of qualifying profit from self-developed intellectual property is deducted, leaving the remaining 20% taxed at the 15% corporate rate, for an effective rate of about 3%. It is OECD-compliant and built on the nexus rule, so the qualifying share depends on the qualifying R&D expenditure behind the IP and who incurred it.
What qualifies, and what does not?
Copyrighted software can qualify: platform code, game engines, trading bridges and proprietary tools. Brands, trademarks and other marketing IP are excluded. The regime is built around technology you wrote, not a licence you resell.
Do our developers have to move to Cyprus?
Not wholesale, but the Cyprus company has to be the one that develops and controls the platform. In practice that means a resident technical lead and a core engineering team approving releases locally, with the Cyprus company funding the work. Development it does itself, or outsources to unrelated third parties, counts toward the qualifying share; development recharged from group companies outside Cyprus does not. You bring the technical leadership; we handle payroll, contracts and the office.
We already own the IP elsewhere. Can we still use the regime?
Usually, and the IP is transferred in at an independent valuation. What you pay to acquire IP that already exists counts toward total development spend without counting toward the qualifying share, so it reduces the share of profit that gets the reduced rate. How that lands on your facts is set out by a regulated Cyprus tax advisor in a formal opinion, alongside your existing advisors, before anything moves.
Is approximately 3% guaranteed?
No. About 3% is the floor rather than a promise: it is what the regime produces when the qualifying share is at or near its maximum, and a smaller share moves the effective rate up, never down. That share follows the development spend behind the IP and who incurred it. A regulated Cyprus tax advisor quantifies your number in a formal opinion before you commit to anything.
What happens to our MGA licence?
It stays exactly where it is, with your operating entities, brands and player relationships. The Cyprus TechCo sits beside the operation: it owns the platform IP and licenses it back to your Malta entities at arm’s length, with the Maltese cost of the move priced up front.
Your licence stays. Your rate changes.
Map it against your Malta setup.
- Does your platform qualify?
- What would your number be?
- What does the Cyprus layer cost to run?
Prefer email? info@blkadvisoryservices.com · +357 25 820785
Spyrou Kyprianou Avenue 67, 4003 Limassol, Cyprus