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BLK Advisory Services · The 3% Advantage

97%

Your licence stays. Your technology gets an EU home banks approve, and keeps what it earns.

For platform groups licensed in Curaçao, Gibraltar or the Isle of Man: we move the technology IP you built into a real Cyprus TechCo. EU-onshore, audited, near 3% effective on qualifying IP profit, and a counterparty your banks, PSPs and partners can approve.

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.

Sound familiar?

A 0% structure that saved tax can cost more in lost business.

We build the EU layer that keeps your banking, your partners and your rate defensible.

2 months
The legal minimum notice an EU payment provider owes you before closing the account. Many give exactly that.
Post-box
Card-scheme rules require a real EEA merchant outlet. A mailbox fails that test.
20–30%
Withholding leaked at source on royalty flows outside the treaty network
Tightening
Visa’s 2026 monitoring thresholds cut tolerated dispute ratios. High-risk portfolios get de-risked first.

Why now

The EU’s front door costs less than the back door.

Cyprus raised its corporate rate to 15% and kept the IP Box. Builders who qualify get one of the strongest onshore-EU packages in Europe, inside a structure banks can read. One call tells you whether yours qualifies.

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.

A structure built to answer the letter before it arrives.

We give compliance teams a file they can approve on the first pass.

A real counterparty

EU-incorporated, Cyprus-audited, IFRS accounts. An operating TechCo with staff, premises and a board.

Flows that explain themselves

We document revenue as royalties under written licences, priced at arm’s length, invoiced and booked. The file answers source-of-funds questions for you.

The KYC gate is the feature

Funds that cannot be evidenced cannot enter. Banks underwrite you as lower risk because of it.

Banks reward the cleanest file. We build yours.

The leak that’s easy to miss

On every €1M of royalties flowing into a treaty-less offshore holdco:

€300,000

can be withheld at source before your 0% ever applies.

We route the same flow through a Cyprus TechCo and the leak closes.

Illustrative. Non-treaty withholding rates typically run 20–30%. A regulated Cyprus tax advisor quantifies your actual exposure in a formal opinion.

A step, not a teardown

What stays. What moves.

Your gaming licence and operation stay where they are. We add an EU technology layer: a Cyprus TechCo owns and develops the platform IP and licenses it to your operating entities at arm’s length.

Stays where it is

  • Your licence in Curaçao, Gibraltar or the Isle of Man, and your regulatory standing
  • Your operating entities, brands and player relationships
  • Your commercial team and day-to-day operations
  • Everything keeps running through the transition

Moves onshore, 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 under written, arm’s-length licences
  • 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 licensed entities keep operating throughout.

First call

First call & KYC

One call and a short document list. Then a straight answer on fit.

Opinion

Independent tax opinion

Regulated Cyprus advisors put the structure and your number on paper.

Set-up

TechCo & banking

We establish your TechCo, banking and the licences back to your operators.

Substance

Substance build

An office, staff on payroll and board control on the island.

Steady state

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.
  • Clean funds, full KYC/AML.Funds that cannot be evidenced cannot enter. Every licensed entity in the group runs full KYC and AML at onboarding.

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.

Does 3% survive the global minimum tax?

While you run it, yes. OECD Pillar Two’s 15% minimum applies only to groups above €750m of consolidated revenue, and companies below that line keep the IP-Box rate. At exit it depends on the buyer: a smaller or PE buyer keeps the benefit, while a very large strategic may absorb you into its Pillar Two group and top the rate up to 15%.

What does it cost to run?

It depends on what the company has to do, and we will not post a number we would then have to qualify. The swing factors are whether you need substance in Cyprus or only a registered entity, whether the ownership chain is straightforward, whether you need banking and of what kind, and the ongoing bookkeeping, payroll, VAT and statutory audit every Cyprus company files. Tell us which of those you need and the quote follows the scope.

Who issues the tax opinion?

A regulated Cyprus tax advisor from BLK’s partner network. BLK Advisory Services is not a licensed tax advisory or audit firm and does not write or sign the opinion; it designs and runs the structure the opinion describes.

We are currently offshore. Can we migrate?

Usually, if the revenue can be evidenced. Migration remediates documentation for legitimate funds; it never cleanses funds that cannot be evidenced. Historical revenue is rebuilt from platform data, PSP statements and contracts into a file banks accept, and full KYC and AML apply at onboarding.

Your licence works

Now make the structure bankable.

  • Does your platform qualify?
  • Where are your flows leaking withholding?
  • What does the Cyprus layer cost to run?
James Hickson, CEO of BLK Advisory Services

James HicksonCEO, BLK Advisory Services

Straight to James, our CEO. No handoff afterwards, and no commitment.

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Prefer email? info@blkadvisoryservices.com · +357 25 820785
Spyrou Kyprianou Avenue 67, 4003 Limassol, Cyprus