What are the opening hours?

Monday 10:00 - 17:00 Tuesday 10:00 - 17:00 Wednesday 10:00 - 17:00 Thursday 10:00 - 17:00 Friday 10:00 - 17:00

https://www.efinance.ee/service-page/efinance-15-your-friday-quick-start

Electronic Finance OÜ - e-Residency Advisory Hub, Tornimäe tn 5, Tallinn (2026)

29/09/2026

𝗪𝗵𝗲𝗻 𝗮 𝗰𝘂𝘀𝘁𝗼𝗺𝗲𝗿 𝗽𝗮𝘆𝘀 𝘁𝗵𝗿𝗼𝘂𝗴𝗵 𝘆𝗼𝘂𝗿 𝗽𝗹𝗮𝘁𝗳𝗼𝗿𝗺, 𝘀𝗼𝗺𝗲𝗯𝗼𝗱𝘆 𝗶𝘀 𝗹𝗲𝗴𝗮𝗹𝗹𝘆 𝘁𝗵𝗲 𝘀𝗲𝗹𝗹𝗲𝗿. 𝗜𝗳 𝗶𝘁 𝗶𝘀 𝘆𝗼𝘂, 𝗩𝗔𝗧 𝗶𝘀 𝗱𝘂𝗲 𝗼𝗻 𝗮𝗹𝗹 𝗼𝗳 𝗶𝘁, 𝗻𝗼𝘁 𝗼𝗻 𝘆𝗼𝘂𝗿 𝗰𝘂𝘁. 𝗧𝗵𝗲 𝗳𝗼𝗿𝗺 𝘁𝗵𝗮𝘁 𝗽𝗹𝗮𝗰𝗲𝘀 𝗮 𝗯𝘂𝘀𝗶𝗻𝗲𝘀𝘀 𝗼𝗻 𝘁𝗵𝗲 𝗺𝗼𝗱𝗲𝗹 𝗺𝗮𝗽 𝗮𝗻𝗱 𝗿𝘂𝗻𝘀 𝘁𝗵𝗲 𝘁𝗵𝗿𝗲𝗲 𝗔𝗿𝘁𝗶𝗰𝗹𝗲 𝟵𝗮 𝗰𝗼𝗻𝗱𝘂𝗰𝘁𝘀 𝗮𝗴𝗮𝗶𝗻𝘀𝘁 𝗶𝘁𝘀 𝗰𝗵𝗲𝗰𝗸𝗼𝘂𝘁.

When a customer pays through your platform, somebody is legally the seller of what they bought. If it is you, VAT is due on all of it, not on your cut. That rule was challenged at the Court of Justice and upheld.

This month we went through what the answer depends on: what a supply is, where you charge, who your customer is when one side pays nothing, what a take rate is really paying for, and what three ordinary product decisions do to all of it.

None of it is answered by your pricing page. The platform literature does not answer it either — those books are about strategy and stop where the tax code starts.

So we wrote the thing that does. The Platform Model Questionnaire: seven steps, about five minutes, no accounting vocabulary. It places you on the thirty-model map, counts what you charge for, and runs the three Art. 9a conducts against the way your checkout actually works.

Within one business day you get a written read: what you are, where your boundaries run, and which two questions are worth a lawyer. It maps what you are; it does not decide your VAT position, and it does not pretend to.

It is free, and it is the first thing we do with every client anyway. The reason to do it now is simple: every answer in it is cheaper to establish while you are designing the checkout than while someone else is reading it.

efinance.ee/assessment

25/09/2026

𝗔 𝗳𝗼𝗿𝘂𝗺, 𝘄𝗲𝗲𝗸𝗹𝘆 𝗹𝗶𝘃𝗲 𝗰𝗮𝗹𝗹𝘀, 𝗮 𝗿𝗲𝘀𝗼𝘂𝗿𝗰𝗲 𝘃𝗮𝘂𝗹𝘁. 𝗧𝗵𝗲 𝘀𝗮𝗺𝗲 𝗽𝗮𝗴𝗲 𝗰𝗮𝗻 𝗯𝗲 𝗱𝗲𝗳𝗲𝗻𝘀𝗶𝗯𝗹𝘆 𝗿𝗲𝗮𝗱 𝘁𝘄𝗼 𝘄𝗮𝘆𝘀, 𝗮𝗻𝗱 𝘁𝗵𝗲 𝗿𝗲𝗮𝗱𝗶𝗻𝗴𝘀 𝗱𝗶𝘃𝗲𝗿𝗴𝗲 𝗼𝗻 𝘁𝗵𝗲 𝘄𝗶𝘁𝗵𝗱𝗿𝗮𝘄𝗮𝗹 𝗿𝗶𝗴𝗵𝘁 𝗮𝗻𝗱 𝗼𝗻 𝘁𝗵𝗲 𝗽𝗹𝗮𝗰𝗲 𝗼𝗳 𝘀𝘂𝗽𝗽𝗹𝘆. 𝗕𝗼𝘁𝗵 𝗿𝗲𝗮𝗱𝗶𝗻𝗴𝘀, 𝗮𝗻𝗱 𝘄𝗵𝗮𝘁 𝗮𝗰𝘁𝘂𝗮𝗹𝗹𝘆 𝘀𝗲𝘁𝘁𝗹𝗲𝘀 𝘁𝗵𝗲 𝗰𝗵𝗼𝗶𝗰𝗲.

She built a professional community: a forum, weekly live calls, a resource vault. €19 a month, cancel anytime, an annual option at a discount.

Her lawyer looked at the same page and saw a members’ club.

Both readings are defensible, which is exactly the problem: they do not stay together downstream.

Read it as content and the 14-day withdrawal right under Directive 2011/83/EU applies. There is an exception for digital content in Art. 16(m), but it needs three things at once — the customer’s prior express consent, their acknowledgement that the right is lost, and your confirmation of the contract on a durable medium. Two out of three is not the exception, and the checkout page is where all three are won or lost.

Read it as admission plus live sessions and a different question opens: recorded material and live meetings are not automatically treated as supplied in the same place, and which rule applies to the live part depends on how it is organised.

Notice what does not decide this. Not the price, not the platform, not what the page is called. The documents decide — if they were written for that purpose, which most terms of service bought as a template were not.

For a business this size that is a short exercise rather than a project: decide what you are selling, then make the checkout, the terms and the invoices all say the same thing. Doing it while there are two hundred members is an afternoon. Doing it at two thousand, with refunds already asked for, is not.

efinance.ee/assessment

Assembled from patterns we keep meeting. Not a client’s story.

22/09/2026

𝗙𝗼𝘂𝗻𝗱𝗲𝗿𝘀 𝘂𝘀𝗲 𝘁𝗵𝗲 𝗹𝗶𝘀𝘁 𝗼𝗳 𝘀𝘂𝗯𝘀𝗰𝗿𝗶𝗽𝘁𝗶𝗼𝗻 𝗮𝗿𝗰𝗵𝗲𝘁𝘆𝗽𝗲𝘀 𝘁𝗼 𝘀𝗲𝘁 𝗮 𝗽𝗿𝗶𝗰𝗲. 𝗪𝗲 𝗿𝗲𝗮𝗱 𝗶𝘁 𝗱𝗶𝗳𝗳𝗲𝗿𝗲𝗻𝘁𝗹𝘆: 𝘄𝗵𝗮𝘁 𝘁𝗵𝗲 𝘀𝘂𝗯𝘀𝗰𝗿𝗶𝗯𝗲𝗿 𝗮𝗰𝘁𝘂𝗮𝗹𝗹𝘆 𝗴𝗲𝘁𝘀 — 𝗰𝗼𝗻𝘁𝗲𝗻𝘁, 𝗮𝗱𝗺𝗶𝘀𝘀𝗶𝗼𝗻, 𝗽𝗿𝗶𝗼𝗿𝗶𝘁𝘆, 𝗮 𝘁𝗮𝘀𝗸 𝗽𝗲𝗿𝗳𝗼𝗿𝗺𝗲𝗱, 𝗼𝗿 𝘀𝘁𝗮𝗻𝗱𝗯𝘆 𝗿𝗲𝗮𝗱𝗶𝗻𝗲𝘀𝘀. 𝗧𝗵𝗼𝘀𝗲 𝗮𝗿𝗲 𝗱𝗶𝗳𝗳𝗲𝗿𝗲𝗻𝘁 𝘁𝗵𝗶𝗻𝗴𝘀 𝗲𝘃𝗲𝗻 𝘄𝗵𝗲𝗻 𝘁𝗵𝗲 𝗯𝗶𝗹𝗹𝗶𝗻𝗴 𝗲𝗻𝗴𝗶𝗻𝗲 𝗶𝘀 𝗶𝗱𝗲𝗻𝘁𝗶𝗰𝗮𝗹.

John Warrillow catalogued nine subscription models. Seven of them are digital, and each sells something different:

• the gated site: content behind a monthly fee;

• the all-you-can-eat library: everything you have, for one price;

• the private club: people pay to be among these particular people;

• front-of-the-line access: people pay to be served first;

• the simplifier: you take a recurring chore off someone and they stop thinking about it;

• the network model: the product is the other members;

• peace of mind: in a normal month nothing is delivered at all — people pay for someone to be ready.

Founders use the list to set a price. Read it for what is actually handed over and it says something else: content, admission, priority, a task performed, standby readiness. Those are five different things, even when the billing engine is identical and the bank statement looks the same.

And most real businesses are not one archetype. A membership sells access to people, weekly calls, a resource library and priority support on one line for one price.

That is the practical test, and it takes ten seconds. Name what your subscriber gets in one word. If you cannot, you are selling a bundle — and a bundle is not automatically treated as one supply, which means someone will eventually decide what it consists of. Better that it is you, in your own documents.

Tell us your archetype and we will show you the questions it usually raises. A structured starting point, not advice on your facts: efinance.ee/assessment

21/09/2026

𝗜𝗻 𝗱𝗶𝗴𝗶𝘁𝗮𝗹 𝗴𝗼𝗼𝗱𝘀, 𝘀𝘂𝗯𝘀𝗰𝗿𝗶𝗽𝘁𝗶𝗼𝗻 𝗱𝗶𝘀𝗽𝗹𝗮𝗰𝗲𝗱 𝗽𝗲𝗿-𝗰𝗼𝗽𝘆 𝘀𝗲𝗹𝗹𝗶𝗻𝗴 𝗳𝗼𝗿 𝗮 𝗰𝗼𝗺𝗺𝗲𝗿𝗰𝗶𝗮𝗹 𝗿𝗲𝗮𝘀𝗼𝗻. 𝗧𝗵𝗲 𝘁𝗮𝘅 𝗰𝗼𝗻𝘀𝗲𝗾𝘂𝗲𝗻𝗰𝗲 𝘁𝘂𝗿𝗻𝗲𝗱 𝗼𝘂𝘁 𝘁𝗼 𝗺𝗮𝘁𝘁𝗲𝗿 𝗺𝗼𝗿𝗲: 𝗮 𝗼𝗻𝗲-𝗼𝗳𝗳 𝘀𝗮𝗹𝗲 𝗶𝘀 𝗼𝗻𝗲 𝗰𝗵𝗮𝗿𝗴𝗲𝗮𝗯𝗹𝗲 𝗲𝘃𝗲𝗻𝘁, 𝗮 𝘀𝘂𝗯𝘀𝗰𝗿𝗶𝗽𝘁𝗶𝗼𝗻 𝗶𝘀 𝘁𝘄𝗲𝗹𝘃𝗲, 𝗮𝗻𝗱 𝗲𝗮𝗰𝗵 𝗼𝗻𝗲 𝗿𝗲-𝗽𝗼𝘀𝗲𝘀 𝘁𝗵𝗲 𝗾𝘂𝗲𝘀𝘁𝗶𝗼𝗻 𝗼𝗳 𝘄𝗵𝗲𝗿𝗲 𝘁𝗵𝗲 𝗰𝘂𝘀𝘁𝗼𝗺𝗲𝗿 𝗶𝘀.

In most marketplace categories commission dominates. Digital goods are the exception: subscriptions and library access keep displacing the per-copy sale.

The commercial reason is boring. When a file costs nothing to reproduce, charging per copy fights the product.

The consequence is not. A one-off sale is a single supply: one moment, one customer location, one obligation, settled and closed.

A subscription is a succession of supplies. Under Art. 64 of the VAT Directive every period creates the obligation again, and every period re-poses the question of where the customer is, under the presumptions in Arts 24a to 24f of Implementing Reg. 282/2011.

Nothing about the product changed. What changed is that a question you used to answer once now has to be answered every month, in every country your subscribers live in, on evidence you have to be able to produce later.

That is a systems requirement, not a pricing one. Your checkout has to capture and keep the location evidence, your accounting has to recognise revenue period by period, and your reporting has to keep up with both.

The price was decided in an afternoon. The obligation repeats every month. It is worth checking that your setup can carry it before the switch, not after the first year of it: efinance.ee/assessment

17/09/2026

𝗜𝗻 𝗙𝗲𝗯𝗿𝘂𝗮𝗿𝘆 𝟮𝟬𝟮𝟯 𝘁𝗵𝗲 𝗖𝗼𝘂𝗿𝘁 𝗼𝗳 𝗝𝘂𝘀𝘁𝗶𝗰𝗲 𝘂𝗽𝗵𝗲𝗹𝗱 𝘁𝗵𝗲 𝗿𝘂𝗹𝗲 𝘁𝗵𝗮𝘁 𝘁𝗿𝗲𝗮𝘁𝘀 𝗮𝗻 𝗶𝗻𝘁𝗲𝗿𝗳𝗮𝗰𝗲 𝗮𝘀 𝘁𝗵𝗲 𝘀𝘂𝗽𝗽𝗹𝗶𝗲𝗿 𝗼𝗳 𝗲𝘃𝗲𝗿𝘆𝘁𝗵𝗶𝗻𝗴 𝘀𝗼𝗹𝗱 𝘁𝗵𝗿𝗼𝘂𝗴𝗵 𝗶𝘁. 𝗪𝗵𝗮𝘁 𝗿𝗲𝗯𝘂𝘁𝘁𝗶𝗻𝗴 𝘁𝗵𝗮𝘁 𝗽𝗿𝗲𝘀𝘂𝗺𝗽𝘁𝗶𝗼𝗻 𝗮𝗰𝘁𝘂𝗮𝗹𝗹𝘆 𝘁𝗮𝗸𝗲𝘀 — 𝗮𝗻𝗱 𝘄𝗵𝘆 𝘁𝗵𝗿𝗲𝗲 𝗽𝗲𝗿𝗳𝗲𝗰𝘁𝗹𝘆 𝗼𝗿𝗱𝗶𝗻𝗮𝗿𝘆 𝗮𝗰𝘁𝘀 𝗿𝗲𝗺𝗼𝘃𝗲 𝘁𝗵𝗲 𝗼𝗽𝘁𝗶𝗼𝗻 𝗲𝗻𝘁𝗶𝗿𝗲𝗹𝘆.

In C-695/20 Fenix International (CJEU, 28 February 2023) a platform kept 20% of what fans paid creators and accounted for VAT on its 20%. It challenged the EU rule that says otherwise. The Court upheld the rule, and VAT fell due on the full amount subscribers had paid.

The rule is Art. 9a of Implementing Reg. 282/2011: for electronically supplied services sold through an interface, the platform is presumed to be acting in its own name — the supplier of everything sold through it. Goods have their own rule in Art. 14a.

The presumption can be rebutted, but it takes two things at the same time, and most people only remember the first.
One: you explicitly name the underlying supplier as the supplier, both in the contractual arrangements and on the invoice or receipt.

Two: you stay out of all three of authorising the charge, authorising the delivery, and setting the general terms. Do any one of them and you are no longer permitted to name anyone else as supplier at all — however carefully the contract is drafted.

Look at what those three things are. Running your own checkout, releasing the download, publishing the terms of sale. They are ordinary product decisions, usually made by engineers on a Tuesday, and no one asks a tax question before making them.

That is the whole point. The difference between accounting for VAT on your commission and accounting for it on everything that passes through you is not decided by your contracts. It is decided by how your checkout was built. A platform moving €1.5m and keeping €150k can be a €1.5m business in the tax office’s eyes.

Worth checking before the release, not after the audit: efinance.ee/assessment

15/09/2026

𝗡𝗼 𝗿𝘂𝗹𝗲 𝗶𝗻 𝗩𝗔𝗧 𝗹𝗮𝘄 𝗿𝗲𝗮𝗱𝘀 𝘆𝗼𝘂𝗿 𝗰𝗼𝗺𝗺𝗶𝘀𝘀𝗶𝗼𝗻 𝗽𝗲𝗿𝗰𝗲𝗻𝘁𝗮𝗴𝗲. 𝗕𝘂𝘁 𝗮 𝗿𝗮𝘁𝗲 𝗿𝘂𝗻𝗻𝗶𝗻𝗴 𝗳𝗿𝗼𝗺 𝗢𝗽𝗲𝗻𝗧𝗮𝗯𝗹𝗲’𝘀 𝟭.𝟵% 𝘁𝗼 𝗚𝗲𝘁𝘁𝘆’𝘀 𝟴𝟬% 𝗶𝘀 𝗮𝗹𝗺𝗼𝘀𝘁 𝗮𝗹𝘄𝗮𝘆𝘀 𝗽𝗮𝗶𝗱 𝗳𝗼𝗿 𝗯𝘆 𝗵𝗼𝘄 𝗺𝘂𝗰𝗵 𝗼𝗳 𝘁𝗵𝗲 𝘁𝗿𝗮𝗻𝘀𝗮𝗰𝘁𝗶𝗼𝗻 𝘁𝗵𝗲 𝗽𝗹𝗮𝘁𝗳𝗼𝗿𝗺 𝗽𝗲𝗿𝗳𝗼𝗿𝗺𝘀 — 𝗮𝗻𝗱 𝘁𝗵𝗮𝘁 𝗱𝗼𝗲𝘀 𝗺𝗮𝘁𝘁𝗲𝗿.

Marketplace commissions run from about 1.9% to 80%. OpenTable sits at the bottom, Shutterstock at 70%; Getty charges 80%.

Headline rates move, so read that table as history. Etsy’s transaction fee is 6.5% today; Steam runs a tiered 30/25/20 by lifetime revenue; and on 18 August 2026 Apple cut its standard EU App Store commission from 30% to 26%.

Across almost 15,000 marketplaces built on one vendor’s software the average is 9% and the median 7%, while the vendor’s twenty highest earners average 14.7%. All of it is a software vendor’s own data, not a market census.

Founders compare themselves against those numbers constantly. The law never does. There is no rule anywhere that reads a commission line, and no percentage that is safe or unsafe in itself.

What the range does tell you is something else. A high rake has to be paid for, and it is paid for with work: at the bottom you introduce two parties and step back, while at 70–80% you host the file, issue the licence, deliver the download and stand behind the result.

And that work is exactly what the law does read. Authorising the charge, authorising the delivery, setting the general terms — any one of those three is enough to change who is treated as the seller (Art. 9a of Implementing Reg. 282/2011).

So your rate is not evidence. It is a mirror. A commission far above the average for your category usually means you are doing more of the transaction than the word intermediary suggests.

You do not need to change the percentage. You need to know what you are being paid for: efinance.ee/assessment

11/09/2026

𝗙𝗿𝗼𝗺 𝟭𝟭 𝗦𝗲𝗽𝘁𝗲𝗺𝗯𝗲𝗿 𝟮𝟬𝟮𝟲 𝘁𝗵𝗲 𝗖𝗥𝗔 𝗿𝗲𝗽𝗼𝗿𝘁𝗶𝗻𝗴 𝗿𝘂𝗹𝗲𝘀 𝗮𝗽𝗽𝗹𝘆. 𝗧𝗵𝗲 𝘁𝘄𝗼 𝗾𝘂𝗲𝘀𝘁𝗶𝗼𝗻𝘀 𝗦𝗮𝗮𝗦 𝗳𝗼𝘂𝗻𝗱𝗲𝗿𝘀 𝗻𝗲𝗲𝗱 𝘁𝗼 𝗮𝗻𝘀𝘄𝗲𝗿: 𝗶𝘀 𝗼𝘂𝗿 𝗽𝗿𝗼𝗱𝘂𝗰𝘁 𝗶𝗻 𝘀𝗰𝗼𝗽𝗲, 𝗮𝗻𝗱 𝘄𝗵𝗮𝘁 𝗰𝗵𝗮𝗻𝗴𝗲𝘀 𝗶𝗳 𝘁𝗵𝗲 𝗰𝗼𝗺𝗽𝗮𝗻𝘆 𝗶𝘀 𝗼𝘂𝘁𝘀𝗶𝗱𝗲 𝘁𝗵𝗲 𝗘𝗨?

From 11 September a new duty starts under the EU Cyber Resilience Act for manufacturers of products with digital elements sold in the EU — including software.

It is triggered by an actively exploited vulnerability: reliable evidence that a malicious actor has already exploited it without the owner’s permission. The same duty applies to incidents harming the product’s ability to protect the availability, authenticity, integrity or confidentiality of data or functions.

Reports go through one platform to the designated CSIRT and ENISA: early warning within 24 hours, fuller notification within 72 hours, and a final report within 14 days of a fix becoming available — or one month for an incident.

Failure sits in the top fine bracket: up to €15m or 2.5% of worldwide annual turnover.

Now the part that decides whether this concerns you.

Are you in scope? Software customers only use in a browser and never install generally sits outside the CRA, under NIS2 instead. Software they download, install or embed is in. Remote data processing is caught where the product cannot perform one of its functions without it.

And which company carries the duty? EU rules can reach developers outside the EU: the manufacturer’s obligations travel with the product onto the EU market. Whoever places it there may also pick up importer duties.

With development in one country and sales in another, that needs deciding on paper.

Both answers take longer than 24 hours to find. That is why you need them before anything happens: efinance.ee/assessment

10/09/2026

𝗛𝗮𝗹𝗳 𝗼𝗳 𝗮𝗹𝗹 𝗺𝗮𝗿𝗸𝗲𝘁𝗽𝗹𝗮𝗰𝗲𝘀 𝗺𝗼𝗻𝗲𝘁𝗶𝘀𝗲 𝗯𝘆 𝗰𝗼𝗺𝗺𝗶𝘀𝘀𝗶𝗼𝗻 𝗼𝗻𝗹𝘆, 𝗮𝗻𝗱 𝗶𝘁 𝗶𝘀 𝗻𝗲𝗮𝗿𝗹𝘆 𝗮𝗹𝘄𝗮𝘆𝘀 𝘁𝗵𝗲 𝘀𝗲𝗹𝗹𝗲𝗿 𝘄𝗵𝗼 𝗽𝗮𝘆𝘀. 𝗜𝘁 𝗶𝘀 𝗲𝗮𝘀𝘆 𝘁𝗼 𝗰𝗼𝗻𝗰𝗹𝘂𝗱𝗲 𝘁𝗵𝗮𝘁 𝘁𝗵𝗲 𝘀𝗲𝗹𝗹𝗲𝗿 𝗶𝘀 𝘁𝗵𝗲 𝗰𝘂𝘀𝘁𝗼𝗺𝗲𝗿 𝗮𝗻𝗱 𝘁𝗵𝗲 𝗯𝘂𝘆𝗲𝗿 𝗶𝘀 𝗷𝘂𝘀𝘁 𝘁𝗿𝗮𝗳𝗳𝗶𝗰. 𝗪𝗵𝘆 𝘁𝗵𝗮𝘁 𝗶𝘀 𝗼𝗻𝗹𝘆 𝗮 𝘀𝘁𝗮𝗿𝘁𝗶𝗻𝗴 𝗽𝗼𝗶𝗻𝘁 𝗶𝗻 𝗹𝗮𝘄, 𝗮𝗻𝗱 𝘄𝗵𝘆 𝘁𝗵𝗲 𝗳𝗿𝗲𝗲 𝘀𝗶𝗱𝗲 𝗶𝘀 𝗼𝗳𝘁𝗲𝗻 𝗮𝗹𝗿𝗲𝗮𝗱𝘆 𝗮 𝗰𝗼𝗻𝘁𝗿𝗮𝗰𝘁𝗶𝗻𝗴 𝗽𝗮𝗿𝘁𝘆.

Close to half of all marketplaces earn only from commission, and it is usually the seller who pays it. The buyer pays the platform nothing.

That invites a convenient conclusion: the seller pays, so the seller is the client, and the buyer is traffic we bring the seller. Commercially, that is true.

But who you charge is a pricing decision. The bill goes to whichever side you have plenty of: eBay charges sellers because buyers were the scarce side, and Airbnb put most of the fee on the guest because apartments were. That is a question of scarcity, not of law.

The law looks at something else: who you are actually supplying. Your contracts and the way the transaction really works decide that. A platform can take nothing from the buyer and still be treated as the supplier to that buyer — if it takes the payment, sets the terms of the deal and stands behind the result.

And here is the half of the idea people miss: someone who has never paid you a cent can still be your counterparty. Directive 2019/770 treats a person who hands over personal data instead of money as a customer. A free account is a contract too: the service has to work the way the sign-up page promised, the user can walk away from it if it does not, and any dispute runs under their rules, not yours.

The practical consequence follows. If your terms of service and the rest of your paperwork are written only for the paying side, half your business is documented. The other half has not gone anywhere, and it has rights.

“Free” is what you decided about price. It decided nothing about your obligations.

Which side is your customer, and which side thinks it is? efinance.ee/assessment

08/09/2026

𝗣𝗹𝗮𝘁𝗳𝗼𝗿𝗺𝘀 𝗰𝗵𝗮𝗿𝗴𝗲 𝗶𝗻 𝗳𝗼𝘂𝗿 𝗽𝗹𝗮𝗰𝗲𝘀: 𝗮𝗰𝗰𝗲𝘀𝘀, 𝗮 𝗰𝘂𝘁 𝗼𝗳 𝘁𝗵𝗲 𝘁𝗿𝗮𝗻𝘀𝗮𝗰𝘁𝗶𝗼𝗻, 𝗽𝗮𝗶𝗱 𝗽𝗿𝗼𝗺𝗼𝘁𝗶𝗼𝗻, 𝗮𝗱𝘃𝗲𝗿𝘁𝗶𝘀𝗶𝗻𝗴. 𝗜𝗻 𝘁𝗵𝗲 𝗮𝗰𝗰𝗼𝘂𝗻𝘁𝘀 𝗶𝘁 𝗼𝗳𝘁𝗲𝗻 𝗹𝗮𝗻𝗱𝘀 𝗮𝘀 𝗼𝗻𝗲 𝗿𝗲𝘃𝗲𝗻𝘂𝗲 𝗹𝗶𝗻𝗲; 𝗶𝗻 𝗩𝗔𝗧 𝗶𝘁 𝗰𝗮𝗻 𝗯𝗲 𝘀𝗲𝘃𝗲𝗿𝗮𝗹 𝗱𝗶𝗳𝗳𝗲𝗿𝗲𝗻𝘁 𝘀𝘂𝗽𝗽𝗹𝗶𝗲𝘀. 𝗧𝗵𝗲 𝘄𝗼𝗿𝗱 𝘁𝗵𝗲 𝘄𝗵𝗼𝗹𝗲 𝗺𝗼𝗻𝘁𝗵 𝗿𝗲𝘀𝘁𝘀 𝗼𝗻, 𝗲𝘅𝗽𝗹𝗮𝗶𝗻𝗲𝗱 𝘁𝗵𝗿𝗼𝘂𝗴𝗵 𝗮𝗻 𝗼𝗿𝗱𝗶𝗻𝗮𝗿𝘆 𝗽𝗮𝘆𝗺𝗲𝗻𝘁 𝗱𝗮𝘀𝗵𝗯𝗼𝗮𝗿𝗱.

One word explains most of the tax surprises we see: supply.

In VAT, every euro you collect is attached to a supply: the specific thing you are treated as having sold. Not what you call it on the pricing page. What it functionally is.

Platforms charge in four places: access (a subscription to be there), a cut of the transaction, enhanced access (placement, promotion, priority), and audience (advertising). That is our own shorthand for the monetisation choices Platform Revolution sets out, not a list the book prints in those words.

Charging at two or three of them at once is ordinary, and all of it often arrives in the accounts as one revenue line.

Each of those can be a different supply, unless one is genuinely ancillary to another. A cut of someone else’s transaction may be intermediation. Or it becomes your own supply, if you do enough of the transaction yourself: authorising the charge to the customer, authorising the delivery, or setting the terms of sale. Any one of those three is enough (Art. 9a of Implementing Reg. 282/2011, for electronically supplied services). We come back to the three later this month.

You can check yourself in an evening. List every kind of payment you take from your payment provider’s dashboard, then look at how many lines they occupy in your VAT return. Four ways of earning and one line is where the conversation starts.

efinance.ee/assessment

04/09/2026

𝗧𝗵𝗲𝗿𝗲 𝗮𝗿𝗲 𝟲,𝟲𝟬𝟬 𝗴𝗮𝗺𝗲 𝘀𝘁𝘂𝗱𝗶𝗼𝘀 𝗶𝗻 𝘁𝗵𝗲 𝗘𝗨, 𝘁𝗵𝗲 𝗮𝘃𝗲𝗿𝗮𝗴𝗲 𝘁𝗲𝗮𝗺 𝗶𝘀 𝗮𝗯𝗼𝘂𝘁 𝗳𝗼𝘂𝗿𝘁𝗲𝗲𝗻 𝗽𝗲𝗼𝗽𝗹𝗲, 𝗮𝗻𝗱 𝗮 𝗴𝗿𝗼𝘄𝗶𝗻𝗴 𝘀𝗵𝗮𝗿𝗲 𝘀𝗲𝗹𝗹 𝗳𝗿𝗼𝗺 𝘁𝗵𝗲𝗶𝗿 𝗼𝘄𝗻 𝘄𝗲𝗯 𝘀𝗵𝗼𝗽. 𝗧𝗵𝗲 𝘀𝗲𝗹𝗹𝗶𝗻𝗴 𝗲𝗻𝘁𝗶𝘁𝘆, 𝗺𝗲𝗮𝗻𝘄𝗵𝗶𝗹𝗲, 𝘂𝘀𝘂𝗮𝗹𝗹𝘆 𝗲𝗻𝗱𝘀 𝘂𝗽 𝗰𝗵𝗼𝘀𝗲𝗻 𝗯𝘆 𝗱𝗲𝗳𝗮𝘂𝗹𝘁. 𝗪𝗵𝗮𝘁 𝘁𝗵𝗮𝘁 𝗰𝗵𝗼𝗶𝗰𝗲 𝗿𝗲𝗮𝗹𝗹𝘆 𝗱𝗲𝗰𝗶𝗱𝗲𝘀 — 𝗮𝗻𝗱 𝘄𝗵𝗮𝘁 𝗶𝘁 𝗱𝗼𝗲𝘀 𝗻𝗼𝘁, 𝗰𝗼𝗻𝘁𝗿𝗮𝗿𝘆 𝘁𝗼 𝗮 𝗰𝗼𝗺𝗺𝗼𝗻 𝗲𝘅𝗽𝗲𝗰𝘁𝗮𝘁𝗶𝗼𝗻.

The EU game industry has reached 6,600 studios employing over 95,000 people, with a combined turnover of €24 billion (EGDF, 2024 data, published 21 August 2026). The average team is about fourteen people. A growing share sell directly from their own web shop rather than only through the big stores.

A web shop is a legal object. Somewhere in your setup there is one company whose name appears on the receipt the player gets, and that name is where the question starts: it is evidence of who is selling, not the whole answer. An engine is chosen deliberately; a selling entity can end up chosen by default.

What that choice actually decides: which entity’s tax residence the revenue sits in; who carries the VAT and OSS obligations and files the returns; which contract the player is entering into; and how the money moves through your accounting and payment setup.

What it does not decide: for sales of digital services to consumers, the VAT generally follows the buyer’s country, not the seller’s. There is one relief for small sellers — while your cross-border sales to consumers elsewhere in the EU stay under €10,000 a year, you may keep charging your own country’s VAT instead. Above that line, the buyer’s country decides. Incorporating in Estonia does not make a German player’s purchase Estonian.

December is the biggest month most studios have, and it is often the month in which cross-border sales pass €10,000 for the first time. From that point the question of whose name is on the receipt stops being theoretical.

Check it before the traffic arrives, not after:
efinance.ee/assessment

Electronic Finance OÜ - e-Residency Advisory Hub

29/09/2026

25/09/2026

22/09/2026

21/09/2026

17/09/2026

15/09/2026

11/09/2026

10/09/2026

08/09/2026

04/09/2026

Address

Opening Hours

Telephone

Website

Alerts

Contact The Business

Shortcuts

Share

Category

Listing takedown request

Monday	10:00 - 17:00
Tuesday	10:00 - 17:00
Wednesday	10:00 - 17:00
Thursday	10:00 - 17:00
Friday	10:00 - 17:00