Merchant of Record (MoR) formation and management representation

Merchant of Record composition support

MoR (Merchant of Record) is a collective sale of digital goods and physical products. OPTi supports MoR formation for clients by utilizing its expertise in MoR formation and risk management through SPC formation.

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Arrangement of issues and strategy planning for MoR (Merchant of Record) use and composition

In recent years, with the expansion of cross-border e-commerce and global supply chains, VAT registration requirements in various countries have become stricter.

These schemes may be used for sales by group companies.

Based on our experience in structuring MoR schemes in Japan and overseas, we work with lawyers, tax accountants, and other experts who are familiar with the relevant fields to formulate schemes.

We are also capable of structuring special purpose companies (SPCs) and joint ventures, and welcome companies considering MoR business to contact us.

This is the best choice for people like you.

Companies wishing to structure their own MoRs

Companies required to report their business to the CXO

Companies feeling at risk with existing MoRs

Companies that want to handle automatic tax calculations and tax returns required for MoR at the same time.

Service Strengths

Experience in MoR structuring


We have experience in structuring MoRs with domestic and foreign MoR companies, as well as in organizing the issues through risk analysis prior to structuring MoRs.

Not only the taxation system but also the legal system


MoR structuring requires risk analysis and structuring from various angles, including consumer protection and personal information protection, as well as taxation. We can provide one-stop services for these issues together with our experts.

Co-Creation Model through SPC Establishment


We would like to build businesses jointly with our clients. For this reason, we can also provide a co-creation model through the establishment of an SPC.

Service Details

OPTi's MoR structuring and risk analysis service provides risk analysis on various aspects from MoR-specific issues. As a result, we will also handle the practicalities of structuring these transactions.

We listen to your company's business and transaction scheme, and propose the most appropriate scheme.


Feasibility Study

To understand the scheme of MoR and conduct a feasibility study of these schemes.

Arrangement of Issues to be Discussed

We will organize the issues to be discussed at the time of MoR introduction.

Positioning Analysis

We examine the positioning and exclusivity of the MoR.

Post-composition practices

MoR practices will be addressed and monitored.

Frequently Asked Questions

Category Title

Q.

Can you respond in Japanese or English?

A.

Yes, all communication can be done in Japanese or English.

Q.

What is the formation of an SPC (Special Purpose Company)?

A.

Merchants of record need to manage a variety of risks, and SPC is a scheme that can be used to manage these risks.

Flow up to the start of service

  • 01

    Contact
    Please feel free to contact us first.
    (Please note that we may not be able to respond to your request due to conflict of interest checks.)

  • 02

    Hearing
    We will discuss with your company and confirm your future vision, target market, and staff holders.

  • 03

    Consulting Services
    We will review your company's case, organize the issues for each sales channel and country, and confirm the composition with various experts.

  • 04

    MoR Construction
    Design and build the MoR. Specifically, this includes the creation of a contract and terms and conditions in line with the business flow. We also select IT vendors and establish a management system after the MoR is built.

  • 05

    MoR Operation/Monitoring
    MoR operation or monitoring and auditing.

Why choose OPTi?

As an international indirect tax firm, OPTi is a collaborating firm of Andersen Global (NYSE: ANDG), and has filed indirect tax returns, provided advice, and handled other legal matters in more than 170 countries around the world. In addition to our experience in implementing various tax technologies, we are strong in MoR issues and risk management through our support for MoR structuring and operation.
We can also provide hands-on support, including the formation of special purpose companies (SPCs).

Requests for MoR composition

The MoR composition is a very complex and sensitive initiative. For this reason, we would like to have someone at the business manager level or above to participate in the project.

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