An iGaming affiliate is a media business, not an operator. You do not take bets, manage players’ balances or organise gambling: you drive traffic and earn commission. The key point here is this: to operate as an affiliate, you need neither a licence to organise gambling nor authorisation from the Tax and Customs Board — a standard Estonian OÜ is sufficient. Anything sold to you under the guise of an ‘affiliate licence’ is either an operator’s licence requiring €1,000,000 in share capital – which you do not need – or nothing at all.
What an affiliate really needs is a legal entity in a straightforward EU jurisdiction that the affiliate programme will accept without question, the correct VAT regime for commissions from around fifteen countries simultaneously, and an accounts team that knows how to handle self-billing reports, multi-currency transactions and payments in stablecoins. Plus, a clear understanding of where the line is drawn for permissible advertising — and that line is defined by the laws of the countries where your audience lives, not by the laws of the country where the company is registered.
We put this structure together on a turnkey basis: we register an OÜ with business descriptions that won’t cause issues when onboarding with payment services, we structure VAT to suit your affiliate programme, and we maintain the accounts so that the reporting reflects actual cash flows.
| Topic | Practical explanation |
|---|---|
| Legal form | OÜ – a private company, 100% foreign-owned, with a share capital of €0.01 or more |
| Licence | Not required: the affiliate provides marketing services and does not organise gambling |
| Income tax | 0% on reinvested profits; 22/78 when dividends are distributed |
| ‘Defence’ tax: 2% | Suspended until it comes into force — there is no additional tax rate on company profits |
| Governance | Fully online: registration, contracts, board resolutions, reporting — via digital signature |
| Commissions for VAT purposes | Advertising and marketing services (general rule on place of supply for B2B) |
| An operator in the EU with a valid VAT number | Reverse charge: 0% VAT, tax payable by the customer |
| Operator outside the EU (Curaçao, Anjouan, the Isle of Man) | Export of services — VAT-exempt |
| VAT threshold in Estonia | €40,000 of taxable turnover — reverse charge commissions are not included in this figure |
| The media buying trap | Purchasing advertising from Google Ireland, Meta and other foreign suppliers creates an obligation to register as a limited-liability VAT payer |
| Advertising | Regulated by the law of the country where the audience is located; in Estonia, advertising by an operator without an Estonian licence is prohibited |
| Operator licence (if you decide to become one) | €1,000,000 in capital for games of chance, two tiers of licences, 8–12 months |
If you have any questions, our managers are always on hand and ready to help! If you’re not sure whether your business model requires VAT registration at this stage, simply submit an enquiry and our specialists will analyse your affiliate and marketplace landscape free of charge.
For tax purposes, an affiliate commission constitutes the provision of advertising and marketing services, and the tax treatment depends on who your payer is. There are four scenarios to distinguish between:
A separate point: self-billing. Most affiliate programmes generate a report and make payments based on it themselves, without waiting for your invoice. This is permissible, but only if there is a self-billing agreement in place and provided that the document contains all the required details. The practical risk lies elsewhere: an affiliate programme’s report is not, by default, an accounting document, and the amount stated in it often does not match the amount actually received due to deductions, chargeback adjustments and negative carryover. Records must be kept for both streams; otherwise, the discrepancy will have to be reconciled manually for the annual report.
The most common misconception regarding the €40,000 threshold is discussed in the next section.
Good news. The €40,000 threshold for compulsory VAT registration is calculated solely on the basis of Estonian taxable supplies. Commissions from EU operators are subject to the reverse charge mechanism and do not constitute taxable supplies in Estonia, whilst commissions from non-EU operators constitute an export of services. This means that an affiliate can earn well over €40,000 a year without being obliged to register as a VAT payer in Estonia. The obligation arises only in the case of Estonian customers or other Estonian taxable supplies.
This is the bad news that hardly anyone writes about. As soon as you purchase services from a foreign supplier — such as advertising from Google Ireland or Meta, subscriptions to tracking tools and SEO tools, services from contractors and traffic exchanges — the place of supply for these services is deemed to be in Estonia, and you are obliged to account for and pay VAT on their value yourself. To do this, a company without standard VAT registration must register as a limited-liability VAT payer, and there is no exemption threshold here. Tax paid in this way is not eligible for deduction — it is a net expense.
Practical conclusion. For a pure SEO affiliate who does not purchase traffic, it is usually more advantageous not to register as a VAT payer at all. For a media buyer, the situation is the opposite: where there are significant expenditure on advertising and tools, full VAT registration is more advantageous – in that case, the input tax under the reverse charge mechanism is deductible rather than being treated as an expense. We’ll calculate both scenarios using your figures and tell you straight up which one works out cheaper for you specifically.
By ordering a package from a single provider, you receive a structure where registration, VAT regime and accounting are tailored to a real monetisation model — rather than cobbled together from bits and pieces, which can lead to commissions being processed incorrectly and input VAT on traffic purchases being lost.
Registering an OÜ — online via e-Residency (usually 1–5 days), at a notary’s office or by power of attorney. For non-residents, a registered office in Estonia and a contact person are mandatory: the address must be a genuine physical address, and the contact person must be a licensed provider who receives official correspondence and is responsible for it. Authorised capital: from €0.01; no resident director is required; 100% foreign ownership.
Please give careful thought to the wording of the business activities and the EMTAK code. ‘Affiliate’ refers to marketing, advertising and media, and this is precisely how the business activities must be described. Wording such as ‘organisation of gambling’ in the articles of association is not only factually incorrect but is also guaranteed to hinder onboarding with payment services.
The Gambling Act regulates the organisation of gambling: taking bets, determining outcomes and paying out winnings. An affiliate does none of these things, so it requires neither an operating licence nor an organisation licence. In Estonia, both licences are issued by the Tax and Customs Board, and are intended for operators.
The actual regulation applicable to affiliates is the advertising law of the country whose audience you are targeting:
Practical conclusion: the affiliate’s legal risk lies not in the ‘licensed/unlicensed’ dichotomy, but in compliance with the rules of target markets and contractual discipline with operators.
| Tax | How it applies |
|---|---|
| Profit tax | 0% on reinvested profits; 22/78 when dividends are distributed |
| VAT, rate | 24% (Estonia’s standard rate) |
| Commissions from EU operators | Reverse charge, 0% (provided a valid VAT number is registered in VIES) |
| Commissions from non-EU operators | Export of services, 0% |
| Commissions from Estonian operators | 24% (if the company is registered as a VAT payer) |
| Purchasing advertising and services abroad | Input reverse charge: you calculate VAT yourself |
| VAT registration threshold | €40,000 of Estonian taxable supplies; there is no threshold for services received from abroad |
| Salaries and contractors | Social security contributions at 33% + unemployment insurance for employment contracts; contracts with self-employed contractors abroad are subject to their own jurisdiction |
The main advantage of the Estonian model for affiliates is deferred taxation. Commissions can be reinvested for years in content, links, traffic acquisition and the purchase of projects, without paying corporation tax. This is particularly valuable for businesses with seasonal fluctuations and sharp downturns: tax is only payable when the money actually flows to the owner.
We set up this accounting system from the very first month – it is this that determines whether the annual report will be a mere formality or a frantic rush.
An Estonian company does not come with an automatic bank account, and a gambling profile increases the level of scrutiny: banks and EMIs apply an in-depth verification procedure, even when you are not an operator but a marketing contractor. What works in practice: an honest description of the business model specifically as marketing services, listing the platforms and affiliate partners; a genuine website and contracts; a clear source of funds; and a separation between the operating account and reserves. We prepare a package of documents for onboarding and advise you on which providers are realistic for your profile. The decision to open an account always rests with the bank or EMI.
an affiliate who has grown into a brand of their own, it is important to understand the scale of the transition. An Estonian operator’s licence involves two stages of authorisation from the Tax and Customs Board, fully paid-up authorised capital of €1,000,000 for games of chance (€130,000 for betting, €25,000 for games of skill), a requirement that the organisation of gambling be the company’s sole activity, integration with government reporting systems and the self-exclusion register, RNG certification, and a realistic timeframe of 8–12 months. The tax on remote gambling is 6 per cent of the total stakes, net of winnings.
This is a separate project in a different league, and we are clear about this: as a corporate service provider, we register and support companies, whilst operator licensing requires a specialist legal team. As for affiliate activities — ranging from a single website to a network of projects with media buying — an Estonian OÜ remains one of the most convenient and cost-effective solutions in the EU.
Tell us about your business model (affiliate programmes, geotargeting, traffic, EU/offshore operators) — within 24 hours we’ll draw up a working plan for your company, including VAT and accounting arrangements, with a budget tailored to your income.
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