Supplemental Legal Opinion on Platform Structure, Commission Model and VAT Treatment
This Addendum supplements the Legal Opinion dated 27 January 2026 issued by Eesti Firma OÜ, assessing the qualification of the HuHu game as a game of skill under Estonian law.
This legal assessment is based on the Terms of Service of HuHu.game, which define the contractual and economic relationship between the platform and its users.
HuHu.game operates as a digital platform providing organizational, technical and administrative services for skill-based game rounds. The platform does not participate in game outcomes and does not act as a gambling operator.
HuHu.game earns revenue exclusively through a commission fee charged for organizing and administering game rounds. Prize pool funds are not revenue of HuHu.game.
For VAT purposes, only the commission fee constitutes consideration for a taxable supply. Prize pool funds fall outside the scope of VAT.
For EU B2C services, VAT is applied under the OSS regime.
The commission-based platform model operated by HuHu.game OÜ is consistent with EU VAT rules and the qualification of the game as a game of skill.