On the 30 September 2026, the Malta Tax and Customs Administration issued new guidance dealing with situations where a supply stops being considered as VAT exempt without credit and becomes VATable . While the guidance is not limited to gambling, its relevance to the industry is clear. In fact, the guidance note specifically provides for an example of an online gaming operator whose sports betting activity transitions from exempt without credit to taxable from 01 October.
The guidance also reinforces the importance of looking beyond the invoice date as the VAT treatment during the transition may also depend on when the underlying service is performed and how the related costs are used. This makes the 01 October cutover both a compliance exercise and a potential VAT recovery opportunity, bringing several practical considerations into focus for gaming operators, particularly: