Gaming, Online Betting

Recent developments in tax administration—particularly the growing use of third-party transaction data, payment systems information, and platform-level reporting—have materially altered the risk profile for gaming operators, payment processors, and investors in the sector.

The Gaming Tax Risk Landscape

Gaming and betting platforms typically involve:

• High transaction volumes
• Real-time digital payments
• Cross-border technology and IP structures
• Reliance on payment service providers, aggregators, and mobile money systems
• Centralised platform operations with local market reach

In jurisdictions such as Uganda and across the region, these features have triggered enhanced regulatory and tax scrutiny, including:

• Use of payment systems and third-party transaction data by tax authorities
• Platform-level reconciliation of gross gaming revenue against declared tax positions
• Increased coordination between tax authorities, regulators, and financial intermediaries
• Aggressive enforcement of sector-specific levies and withholding obligations

Gaming taxation has therefore become a data-driven enforcement exercise, not a self-assessment environment.

MRT Tax advises gaming, betting, and digital wagering businesses on tax structuring, compliance, audit defence, and dispute resolution, with a particular focus on how revenue authorities actually enforce digital economy taxation in practice.

We advise on the applicability and interaction of:

• Digital services taxes
• Gaming and betting-specific turnover or gross revenue taxes
• Sector levies imposed on non-resident digital operators

Gaming operators frequently face PE assertions arising from:

• Local agents, promoters, or marketing partners
• Payment intermediaries and transaction processing arrangements
• Technology infrastructure and data flows linked to local markets

Transfer pricing issues in the gaming sector often centre on:

• IP ownership and licensing of gaming software
• Platform fees, revenue-sharing arrangements, and risk allocation
• Centralised vs localised operational models

Gaming platforms often involve complex cross-border payment flows, including:

• Payments to offshore platform operators
• Fees to technology providers and payment processors
• Revenue shares and affiliate commissions
• Withholding tax exposure
• Audit defence where payment data is already in the possession of tax authorities