ECA European Casino Industry Report 2013

ECAS EUROPEAN CASINO
INDUSTRY REPORT
2013
Prepared by
ECAS EUROPEAN CASINO INDUSTRY REPORT
he European Casino Association (ECA) is proud to present to you the first ECA European Casino
Industry Report. This report represents a milestone in the history of ECA since it is the first
time that so much information from all of our member countries has been compiled into one
complete overview of the European casino industry.
ECA represents the interests of approximately 800 casinos and 55,000 employees in 23 countries
across Europe. As such it has become the voice of the licensed European casino industry, with its
key role being the point of interaction between European institutions and stakeholders. ECA is the
thought leader and unified voice for Europes licensed casino industry. We at ECA promote a secure,
regulated gaming environment, the highest responsible gaming standards, and a sustainable and
fair business environment for the industry by proactively shaping policy frameworks and regulations.
In other words, ECA strengthens the image of Europes licensed casino industry as being a business
of integrity dedicated to such values as transparency, responsibility and safety.
It is in keeping with this mandate, that all ECA members (and NCF*) have assisted in bringing this information together, collectively
offering a comprehensive account of the state of the European casino industry. Overall support was given by two of our Associate
Members, Herzfeld Consulting and Gambling Compliance.
The result is a transparent picture of the licensed European casinos that not only includes the Gross Gaming Revenues of the
industry, but also the information essential to a well-controlled and regulated gaming environment.
Further, the report touches upon the important contributions made to society by licensed European casinos. A few examples of such
contributions are taxes and direct and indirect employment, as well as the sponsoring of social, cultural and sporting events.
In order to be able to capture the full picture of the European gaming industry, it would be necessary for all sectors to provide
similar audited information. Therefore, ECA calls on all other sectors of the European gaming industry, where this is not yet common
practice, to follow suit. This effort would help to put an end to all of the speculation and guessing about the size and revenues of the
various parts of the gaming industry in Europe and would provide a valuable tool for all key decision makers and stakeholders.
In line with the latest European Parliament report on online gambling, ECA fully supports the need for a clear definition of what it
takes to be a legal gambling operator. First and foremost, the operator must have a license to operate in the Member State of the
player. Furthermore, the operator must not be definable as illegal with respect to the applicable law and procedures of any other
Member State.
Considering the nature of online gambling, it might be advisable to come to a definition on the legality of gambling operators on a
much broader scale than the European Economic Area.
The European casino industry has seen difficult times with the introduction of smoking bans and the start of the economic crisis in
2008 and the ever growing competition, partly from less regulated or unregulated forms of gaming. But the industry has shown
strong resilience over the years and companies have clearly responded to the need for change. Despite the ongoing times of
uncertainty, it is promising to see that about 40 percent of our member countries have shown an increase in Gross Gaming Revenues
in 2012 compared to the previous year. Obviously there is still a long way to go, but looking at the overall creativity that has gone into
improving the business, as well as the increasing levels of service to our customers across the European casino industry, the upturn is
encouraging.
We hope that this first issue of the ECA European Casino Industry Report can serve as a helpful reference tool for you.
Ron Goudsmit
Chairman, European Casino Association
*National Casino Forum, UK
European Casino Industry Report
ABOUT THIS REPORT

ECA
GamblingCompliance Research Services
The ECA, the European Casino Association (www.

europeancasinoassociation.org), is a non-profit organisation
seated in Brussels, which represents the interests of almost 800
casinos and approximately 55,000 employees across Europe.
Founded in the early 90s as the European Casino Forum, the ECA
has gradually grown over the years and today includes members
from the majority of the EUs member states as well as from
Switzerland and Serbia.
Authors
Andrew Gellatly
Daniel Macadam
Lina Sennevall
Tony Batt
Daniel Stone
The main purpose and objective of the ECA is to address

issues related to casinos and / or casino operations with the
European institutions, and in doing so, to provide a focal point
on casino matters for casino operators as well as for EU and
national policymakers and stakeholders. To this end, the ECA
aims to serve as a network, communicate and work with the EU
institutions on anything related to casino operations.
Within said purpose the association aims to:

Collect and provide information on casino operations and

casino administration including assessment of European
and national legislation and regulations addressing casino
operations
Increase awareness and understanding of the casino
industry amongst EU policy makers and stakeholders
Constructively contribute to EU decision making on matters
affecting the casino sector
The ECA is, amongst other things, active in many different areas
related to gambling policy.
Furthermore the ECA advocates for solid consumer protection
measures in the field of gambling by ensuring the member
states are in a position to enforce measures against illegal
gambling. The fight against illegal gambling is one of the key
priorities for the ECA members, as well as ensuring a certain
level playing field between the different actors in the gambling
market.
European Casino Association
Rond Point Schuman 9
1040 Brussels
Belgium
Tel. +32 2 541 03 32
Mobile: +32 (0)479 71 00 58
Fax +32 2 538 49 80
info@europeancasinoassociation.org
www.europeancasinoassociation.org
Editing
Louise Coleman
Hannah Frost
Gambling Compliance Research Services is a full service
provider of legal, regulatory, political and business insight for
the global gambling industry.
Based in London, Washington D.C., California and Taipei, we
offer existing market participants, regulators, governments
and investors easily accessible and up-to-date information on
market realities, and a reliable and independent listening post to
monitor legislative developments at local level.
Tracking regulatory change across the global gambling industry
is our core business, which means we can provide immediate
access to an independent, cost effective and skilled team to
deliver tailored research reports.
Commissioned research from GCRS could help you:

Track gambling legislation and regulation across

jurisdictions and anticipate and respond to legislative
developments
Compare key facets of legislation and regulation across
jurisdictions
Grasp the political fundamentals driving legislative
movements
Gauge the size and growth trajectory of gambling markets
via product-specific data forecasts
Contact us to find out more: research@gamblingcompliance.com

www.gamblingcompliance.com
Herzfeld Consulting
Paul Herzfeld has been CEO of an international casino and
gaming group, responsible for its expansion into new markets
and the development of projects in Europe, Middle East,
Australia, South Africa, Canada and South America.
With his company Herzfeld Consulting (www.herzfeldconsulting.com) and based on more than 35 years of experience
in the gaming industry he provides services for international
gaming companies. Herzfeld Consulting is specialised in the
fields of strategy consulting, identifying suitable business
models, efficient search for investors, launching productive
cooperations and entry into new markets. Herzfeld Consulting
is proud to be an associate member of the European Casino
Association (www.europeancasinoassociation.org).
www.herzfeld-consulting.com
USE OF INFORMATION WITHIN THIS REPORT

In preparing this report the European Casino Association,
GamblingCompliance and Herzfeld Consulting have made
every reasonable effort to ensure the accuracy of the contents.
However, no representation or warranty (express or implied)
is given as to the accuracy or completeness of the information
contained in this report. Furthermore, the European Casino
Association, GamblingCompliance and Herzfeld Consulting
do not intend this report to be interpreted, by any reader
as constituting legal advice. Any reader, or their associated
corporate entity, who relies on any information contained in
this report does so entirely at their own risk. The European
Casino Association, GamblingCompliance and Herzfeld
Consulting and its employees do not accept or assume any
liability, responsibility or duty of care for any consequences of
you or anyone else acting, or refraining to act, in reliance on the
information contained substitute for local legal advice in each
jurisdiction covered. Before acting or refraining to act on any
information you read in this report it is strongly recommended
that you obtain independent legal advice. Finally, the content of
this report is based on information available at the time it was
drafted and does not prejudge any modifications or amendments
in any form whatsoever that may be implemented after the
drafting of this report and which may influence its content.
The European Casino Association, GamblingCompliance and
Herzfeld Consulting may not be held liable for any of the said
modifications or amendments.
Copyright 2013 European Casino Association. All rights
reserved. This report may be: (i) copied, photocopied or
duplicated in any form by any means; or (ii) redistributed or
republished.
CONTENTS
ECAs European Casino Industry Report
Hungary55
Casinos Seeing Signs of Recovery
10
Italy59
US Building Boardwalk Empire on Belgian Inspiration
12
Lithuania
63
Europe Tempted by Singapore Sling
14
Luxembourg
67
Europes Casinos Battle Online Tax Mismatch
16
Netherlands
71
Jurisdictions
Poland
75
Austria19
Portugal
79
Belgium23
Romania
83
Czech Republic
Serbia
87
27
Denmark31
Slovakia91
Estonia35
Slovenia95
Finland39
Spain99
France43
Sweden103
Germany
Switzerland
107
United Kingdom
111
47
Greece51
CASINOS SEEING SIGNS OF RECOVERY

By Andrew Gellatly
A
crisis.
tight focus on operational efficiencies and

driving visitation is helping Europes
casinos rebound from the eurozone
Nearly five years on from the start of an

economic downturn that has knocked
the economic lives of millions off course,
Europes casino industry has readjusted and
is just beginning to navigate its way out of the
extended downturn.
Figures from 2012 showed declines in casino
revenues in 12 EU countries, and deep contractions in
Greece, Italy and Switzerland, but eight members, or 40 percent
of the ECAs countries were able to grow their gross gaming
revenues.
All the casinos combined in the European Casino Associations
23 member countries generated consolidated gaming revenues
of 6.58bn in 2012 6.5 percent less than the year before.
Some countries are picking up or stabilising and

40 percent of our members reported increased
gaming revenues in 2012, said Ron Goudsmit,
the casino associations chairman.
Goudsmit contends that casinos across Europe have been hit to

varying degrees by smoking bans, competition from online rivals
and slot arcades, as well as the widespread economic malaise.
More than 80 percent of last years 6.58bn total was generated
in just eight countries, with Frances 195 casinos contributing
2.34bn, or 35 percent, while Germany, Switzerland, the
Netherlands, Italy, Greece, Spain and Portugal accounted for
between 4 and 10 percent each.
eight of these leading countries posted year-on-year

falls in casino gross gaming revenue.
The deepest declines in absolute terms came
in Greece, Italy and Switzerland, where
casinos have been slammed with a triple bill
of expanded gambling offerings, stuttering
consumer confidence levels and a boom in
online gaming from which they have been
largely excluded.
Greek casino revenues fell by more than a fifth to
339m last year, compared with a 19 percent drop in
Italy to 449m as both countries failed to rebound from the
downturn.
In Switzerland, where a strong Swiss franc and strong
competition from border casinos has seen players take their
business elsewhere, the domestic casino market shrank 11.5
percent to 623m.
Casino operators increasingly also felt there is a causal link
between increased popularity of online casinos and lower landbased revenues.
How do you break it out? There are no reliable audited data on
online activity or the effect it is having, but even without figures
you can tell its influencing your business, said Goudsmit, who
is also senior vice president of international development at
Holland Casino.
Although overall spend on casino games has stabilised in Italy
over the past three years, since the introduction of online casino
offerings in December 2012, an increasingly large segment of
that spend has found its way to online operators, while landbased providers have seen their share fall away.
Now Italys largest casino by turnover, Campione dItalia, close

to the affluent Milan market, saw sales fall 16.5 percent in 2012
but visitor numbers fell just 3 percent to 664,000, as a result
of its hosting of the Italian Poker Tour organised by Titan Bet,
as well as a strategy of actively targeting Chinese and Russian
visitors.
Pressure has come from land-based rivals too, as seen in
countries such as Germany where arcades have annual revenue
of 4.3bn compared with the 625m generated by 73 casinos.
In a lot of countries the arcade business is enormous and thats
also competition people tend to forget, even though the stakes
are lower, Goudsmit said.
Hungarys three casinos were helped enormously by the
governments abrupt ban in October of all slot machines outside
casinos. Of all the European countries, the largest year-on-year
gain in both absolute and relative terms was seen in Hungary
up 7m, or 32 percent, to 29m.
After winning 12 of the 15 Austrian casino licences in a Europewide tender process, Casinos Austria will be allowed to close
the loss-making casino in Bad Gastein but open another at the
Grand Hotel in Zell am See.
The casino in Bad Gastein, a small operation which is only open
in high season, is expected to close at the end of 2015.
Casinos Austria hopes the replacement in Zell am See will
benefit from wealthy Russian and Middle Eastern visitors.
Spokesman Martin Himmelbauer said: After careful
consideration we have decided on Salzburg for a change of
location. We just see more potential for a good year-round
occupancy at Zell am See.
Casinos Austria saw turnover at its 12 domestic casinos
contract slightly from 279.7m in 2011 to
273.9m in 2012.
Still, many thousands of disconnected machines have since

made their way across Hungarian borders to neighbouring
Slovenia and Slovakia, piling additional pressure onto the casino
operators there.
According to Goudsmit, the residual effects of smoking bans
are still being felt in many markets, further delaying hopes of
recovery, at the moment when a smoking ban starts and
we have seen it in several instances and particularly on slots
revenues go down 15-20 percent, so only in thee to four years, if
at all, are you back at the level where you first started.
For some operators the renewals of their licences have given
them a chance to rationalise their operations and focus on their
most profitable markets.
In a clear sign of the turbulence still battering the industry, all

10
Still, in Italy, the casinos, seeking increases in visitation at a time

when spend per visit is falling, have done their best to partner with
dominant online operators to offer poker tournaments in their
properties, a strategy that has been successful in staunching a
decline in visitor numbers, particularly at Casino Campione.
Greek casinos have not shared in the rebound in tourism

revenues that have been experienced elsewhere in the country.
11
US BUILDING BOARDWALK EMPIRE ON

BELGIAN INSPIRATION
By Andrew Gellatly and Daniel Macadam
lthough it is early days, US gambling jurisdictions appear

more ready to reserve their online gambling licences for
existing land-based operators, following the pioneering
example set in Europe by Belgium.
It has been largely overlooked by its European neighbours,
but Belgiums careful approach to licensing online gambling
operators by linking them to the operations of land-based
casinos is being replayed in the United States and is about
to debut in one of the worlds foremost casino gambling
jurisdictions.
online, and far ahead of Italy where online revenues are less
than 6.5 percent of the industrys overall take.
The key factor why its been a success is that from a regulatory
point of view we have kept sufficient control of operators and
the online market, said Peter Naessens, head of the Belgian
gambling commissions regulatory advice unit.
He added that gambling websites healthy revenue came even
with that level of control, with the restrictions on the operators.
Belgium introduced nine A+ licences, which cover a wide

range of online casino and poker games, for the countrys nine
casino properties in 2011, and has since seen PokerStars, Bwin.
Party, Unibet and WMS all sign tie-ups with the Belgian casino
operators. In New Jersey nine of the Atlantic Citys 12 casino
properties have done similar deals ahead of a market opening
slated for the end of November 2013.
The boss of Circus Group added that it was absolutely fair

that online firms should only be allowed to operate through
partnerships with land-based businesses.
This is social justice. Its a competition and we started this
competition with a huge handicap, Mewissen said.
The most recent figures show a strong measure of success for
the Belgian system which claims 400,000 registered players.
In 2012 online gambling gross gaming revenues are on track to
be between 100m and 120m, with land-based GGR expected
to hit 400m. An online market share of more than 20 percent
puts Belgium up with the UK, the most mature online gambling
market in the EU ,where 29 percent of gambling spend happens
They were just doing what they were doing, acting on their
economic and regulatory interests, Dayanim said.
Other US jurisdictions too are taking the same route, reserving
online gambling licences for existing land-based operators.
In Nevada online poker licences can only be obtained by casinoresorts, while in Delaware internet gambling is being controlled by
the states lottery in partnership with the states three racetracks.
Many EU countries have rejected the so-called licence plus model

where casinos and other land-based firms receive online operator
licences and online specialists must then partner with them.
The strategy of Circus, which operates casinos in Spa and Namur

in Belgium, has been to take popular Belgian games and launch
them online, and is now reporting higher traffic to its casino777
website than PokerStars Belgian website.
But this is not the case everywhere and especially not in the US,
said Mewissen, who observes that the New Jersey casinos are
facing the exact same problem, as their European counterparts.
We felt we could not compete with Microgaming or Playtech,

so we decided to do what we are good at, which is local games,
said Mewissen.
Although they are 5,000 kilometres and a cultural ocean apart,

New Jersey and Belgium have both chosen to regulate their
nascent online markets by putting their land-based licensees
firmly in the driving seat.
Joe Kelly, a business law professor at SUNY College in Buffalo,
said New Jerseys decision to only license brick and mortar
casinos for internet gambling was in part made because of the
political muscle of the gaming industry in Atlantic City.
Behnam Dayanim, a gaming attorney in Washington, D.C.,

agreed the major factor in New Jerseys decision to grant internet
gambling licences to land-based casinos was the states desire
to revitalise the ailing gaming industry in Atlantic City.
Atlantic Citys attractions now include online gaming.

Dayanim said he would be surprised if New Jersey regulators

are even aware of Belgiums regulatory procedures, but said the
decision made sense on its own merits.
In every case, as in Belgium, established online gambling

companies have been quick to ink partnerships with land-based
gaming companies.
Remember, the only way this [legislation] was able to get through
New Jersey was to give the casinos all the 12 casinos the almost
total power to decide whether they wanted to go or not go, and to
the best of my knowledge, nine of them have, Kelly said.
12
Its a new era, a new game.

The cards are redistributed,
but at least with this system
you do not kill the people who
play properly, said Emmanuel
Mewissen, CEO, Circus Group
California is currently considering legislation that would limit

online poker licences to Native American casinos, card rooms
and, possibly, racing groups.
The casino industry is suffering a lot. Most people will not

survive if they do not enter the online industry, said Emmanuel
Mewissen, the chief executive of Circus Group, which has chosen
Isle of Man-based PokerStars as its casino partner in Belgium.
Its a new era, a new game. The cards are redistributed, but at least
with this system you do not kill the people who play properly.
Secondly, there is a higher comfort level among regulators with

existing licensees, Dayanim said. This is a new area of gaming, and
regulators want to deal with the known rather than the unknown.
New Jerseys Planned Online Partnerships

Casino
Owner
Platform Provider/
Partners
Brands*
Borgata
Boyd Gaming
BwinParty
Borgata, PartyPoker
Ballys
Caesars Entertainment
888/AAPN
WSOP, Harrahs,
888, Wynn
Caesars
Amaya
Caesars
Harrahs
Showboat
Resorts
DGMB Casino
Rational Group
PokerStars
Trump Taj Mahal
Trump Entertainment
Ultimate Gaming
Ultimate Casino/
Poker
Trump Plaza
Trump Entertainment
Betfair/GameAccount/
Amaya
Betfair
Golden Nugget
Landrys
Bally/Amaya
Golden Nugget
Tropicana
Tropicana Entertainment
Gamesys
Tropicana, Virgin
Revel
Revel Entertainment
Atlantic Club
Colony Capital
Source: GamblingCompliance, company news
*up to 5 permitted
13
EUROPE TEMPTED BY SINGAPORE SLING

By Daniel Macadam
Governments in all three countries have taken steps to re-write

their gambling laws to offer incentives for the super casinos; the
most recent being provisions passed in Catalonia for a heavily
reduced 10 percent casino tax rate.
Barcelona World, the brainchild of Spanish real estate billionaire
Enrique Banuelos, has the backing of Hong Kong-listed Melco
International, which operates Macaus Altira casino and City
of Dreams, the third highest earning resort in the only place in
mainland China where casino gambling is legal.
Spanish hotel chain Melia and shopping mall specialists Value
Retail are also signed up to the proposed 300,000-square metre
resort an hours drive outside Barcelona.
ome of the worlds largest casino operators are now

looking to invest in integrated casino resorts in Europe
as indebted eurozone countries turn to the industry for a
much-needed boost to tourism and employment.
The concept of integrated resorts has proved hugely successful
in boosting visitation and hotel stays in Singapore, where the
term integrated resort was coined by Las Vegas Sands (LVS)
boss Sheldon Adelson, and the company is now pursuing plans
for an even more ambitious, multi-billion euro casino complex
in Madrid. Dubbed EuroVegas, the resort would revolutionise
the way casinos are perceived in Europe, but it must first succeed
where many casino operators have failed before.
Rival US casino giant Caesars had plans for a Don Quixote
casino-resort in Spain, as did the Gran Scala consortium. Both
groups ambitions to build Europes answer to Las Vegas
crashed amid the 2008 financial crisis and the collapse of
Spains property boom. Elsewhere, the
UKs u-turn on a super casino in
Blackpool, chronic delays for
the Vegas in Europe project
in Hungary, and Russias
failed experiment with
casino zones, except
for Vladivostok on the
Chinese border, all
show the difficulties
of pulling off the
legislative and financial
feats necessary for such
ambitious developments.
In Madrid, the regional parliament passed a law at the end of

2012 setting out key licensing conditions for an integrated resort.
With a capital investment of up to $9bn to cover four integrated
resort casinos and as many as 12,000 hotel rooms in its first
phase, EuroVegas would dwarf its Catalan competitor.
Its something we have to think about at a time

in Spain when there are millions of unemployed
people, said Javier Fernandez-Lasquetty,
Madrids top health official.
Southern Cyprus has held a long-standing ban on casinos in

stark contrast to the northern part of the island occupied by
Turkey. But a new government elected in 2013 has decided to
allow casinos as part of a wider economic stimulus plan.
Conservative President Nicos Anastasiades and his ministerial

team hope that the casino-resort will attract half a million
tourists, largely from Europe and the Middle East, and create
an extra 3,000 jobs. Ministers approved the move in July 2013
with the intention of fast-tracking the international licensing
procedure and finishing within 12 months.
Slovenia has also sped up its plans to generate investment for
large-scale casino projects as the indebted eurozone country
seeks to attract an influx of foreign capital. A new draft bill, set
to replace a 1995 act, would liberalise ownership restrictions
for land-based casinos to allow greater percentages of foreign
ownership, although larger shares would need to be approved
by the Finance Ministry.
Slovenia has long tried to lure tourists across the border from
neighbouring Italy, but current rules have limited foreign
ownership of casinos to 49 percent. The proposed bill, rolled
out by the Finance Ministry in September 2013, would allow
construction of large casinos to be regulated separately.
However, the question of financing still needs to be resolved.

LVS chairman and chief executive Sheldon Adelson was coy
about the projects prospects in an earnings call in October
2013, simply saying it relied on the final, government-approved
grants and incentive package. Adelson has previously said LVS
would expect 30-50 percent to be covered by public funds.
Financing the ambitious EuroVegas complex would be made
more difficult if the company was simultaneously to bid for a
casino-resort in Japan, or even Taiwan, where Asian gambling
growth rates would outpace those seen in Europe. Renewed
momentum around Japanese casino legislation in particular has
taken some focus off the Madrid plans.
Spain, Cyprus and

Slovenia are now actively
pursuing investment from major
international casino firms in a bid to
drive tourism and give local
economies, which in some
Tourist visitation has increased by 60 percent in Singapore
since the two integrated resorts opened in 2010.
cases are heavily in debt, a
major jolt.
14
casino tax from 55 percent of gross revenues to 10 percent

as an incentive for Barcelona World. Like the Madrid project,
Barcelona World fired the imaginations of opposition parties
in Catalonia as legislation went through parliament, with
politicians arguing that the resort would only fatten the pockets
of speculators and mafiosa.
Spains smoking laws also remain a

sticking point. Government officials
in the Madrid autonomous
community have argued that
a carve-out from Spains
federal ban on smoking
inside public places
would help secure
thousands of jobs. Its
something we have to
think about, Madrids
top health official Javier
Fernandez-Lasquetty
said in May, at a time
in Spain when there are
millions of unemployed
people.
At the same time, proposed casinoresorts have a knock-on effect for
the tax affairs of casinos in the same
region. Catalonias regional parliament
approved a bill in October 2013 to cut
15
EUROPES CASINOS BATTLE ONLINE

TAX MISMATCH
By Lina Sennevall
n Denmark online casino operators pay tax at a level only

around one quarter of that paid by land-based casinos and
arcades; a situation that has been sanctioned by the European
Commissions competition watchdog. The case is headed for
appeal and the outcome could be transformative for the highlytaxed casino industry across Europe.
The Court of Justice of the European Union (CJEU) is expected to
rule in the first half of 2014 on whether Denmarks substantially
lower tax rate for online casinos compared to land-based
casinos and slot arcades amounts to illegal state aid.
Victory for Danish casino firm Royal Scandinavian Casino rhus,
which is suing the European Commission, would set a precedent
throughout Europe for aligning tax burdens more equally.
The case was appealed to the CJEU by Casino rhus and the
Danish Gaming Association (DAB) weeks after a ruling from the
European Commission in September 2011.
The EUs executive body found that Denmarks differential tax
rate did amount to state aid, but that it was also compatible with
EU rules because the positive effects of attracting online firms
onshore outweighed the distortions of competition.
Its not too much to ask for the government to

modify the worst part of the legislation and bring
it more in line with EU law, said Bertil Jacobi, the
lawyer representing Casino rhus.
With the commissions blessing, Denmark went ahead and

taxed online operators at 20 percent of gambling revenue, while
land-based casinos and gaming halls remained subject to a tax
which rises up to 75 percent.
However, Bertil Jacobi, the lawyer representing Casino rhus,
has expressed optimism that Europes highest court will now
overturn the commissions reasoning on state aid.
I think theres good reason to believe that we will win the case,
because the rules are so different for online and land-based and
the tax rate should be closer to each other, Jacobi said. Its not
too much to ask for the government to modify the worst part of
the legislation and bring it more in line with EU law.
Jacobi added that he was hoping the final hearing in Luxembourg
would happen before Christmas 2013, after which the court will
take up to three months to deliver its judgment.
Best case scenario the court will have given its judgment in April
and worst case July, he said.
Online & Land-based Casino Tax Comparison
Country
Online Casino
GGR Tax
Land-based Casino GGR Tax
Belgium
11%
2.75-4.8% for table games

20-50% for gaming machines
Denmark
20%
45% up to DKK4m
75% above DKK4m
Netherlands
20% (proposed)
29%
United
Kingdom
15% (proposed)
15-50%
Source: GamblingCompliance
Its the first case about differential tax treatment

for online and offline so it will be the first time an
EU court hears the arguments on this topic, said
Pieter Paepe, an expert on EU law at Astrea law
firm
Pieter Paepe, an expert on EU law at Brussels-based Astrea

law firm, said: At least from the European Commissions point
of view they see it as very important. Its the first case about
differential tax treatment for online and offline so it will be the
first time an EU court hears the arguments on this topic.
Behind the case there are also difficult decisions for
governments that are anxious not to lose any tax revenue, many
of which have become used to taxing casinos at more than 50

percent of revenues.
Either the Danish state loses a lot of revenue or they will lose
all licensed online operators, said Danish lawyer Henrik Norsk
Hoffmann, founder of HNH Law.
The online markets in Europe are not big enough yet so in that
battle I think most regulators would say Too bad for the online
operators. Theres too much money at stake from the landbased guys.
Among Casino rhus six pleas to the CJEU is that the
commission misused its powers by overlooking that Denmarks
tax differential was designed to generate as much tax revenue as
possible rather than as much economic benefit. It is an argument
that resonates for the hundreds of Europes land-based casinos,
as they continue to grapple with low-tax, online competition.
A positive ruling for Casino rhus and DAB would send

shockwaves throughout the European gambling industry and
could force governments to overhaul their tax rates.
Land-based casinos are taxed at a higher rate than web
operators in almost every EU country where online gambling
is under a newly regulated licensing model, including Spain,
Belgium, Italy, France and the UK. One of the few exceptions
Bulgaria changed its mind in October 2013 and announced
it would cut taxes for online gambling, but not land-based slot
machines.
Differential tax rates are highly contentious in countries like the
Netherlands where governments are still designing their online
gambling regimes. Holland Casino has strongly opposed plans
to tax online gambling at a 20 percent headline rate, while
keeping land-based casinos at 29 percent.
A draft bill, which includes the differential tax, will likely be under
scrutiny in the Dutch parliament at the same time as a judgment
is handed down in the Danish case.
Holland Casino and the Dutch slot association VAN have
threatened to seek legal recourse over the taxs unfair
competition in a joint letter to the Dutch finance minister.
If they go to court, I think that a Dutch judge would rule in
favour of Holland Casino and the slot business because theyre
talking about unfair competition. In this case I think it is state
aid, said Tjeerd Veenstra, a former senior director at de Lotto,
the Dutch betting monopoly.
At the heart of the Danish case is the question: how far should
offline and online gambling be treated as two different sectors?
The European Commission said it believes tax rates can be skewed between online and offline if the whole market benefits.
16
17
AUSTRIA
The Austrian gambling market is dominated by casino and

lottery gambling, which is monopolised and regulated
federally, as well as slot machines outside casinos and
sports betting, which are regulated at a provincial level.
Casinos Austria, the former sole concessionaire
for casinos, has now retained control of 12 out
of 15 of the countrys casino operating licences
following a Europe-wide licensing process.
Fewer players visited Casinos Austria in 2012 than the
year before, the 2,324,000 guests representing a slight
decrease compared with 2,362,000 in 2011.
Linz
Bregenz
Salzburg
Seefeld
Kleinwalsertal
Kitzbuhel
Innsbruck Bad Gastein
Graz
Velden
At its 12 Austrian casinos, on 233 tables and on 1,955 slot

machines, Casinos Austria saw turnover contract slightly
from 279.7m in 2011 to 273.9m in 2012.
Online casino gambling can only be offered
by Austrian Lotteries win2day website.
In 2012 an Austrian High Court ordered online operator
Bet-at-Home to pay back 1m to a losing punter because
the Malta-licensed firm did not have a licence to operate
online casino games in the country.
Vienna
Baden
Casino Bad Gastein

Casino Baden
Casino Bregenz
Casino Graz
Casino Innsbruck
Casino Kitzbuhel
Casino Kleinwalsertal
Casino Linz
Casino Salzburg
Casino Seefeld
Casino Velden
Casino Vienna
19

Market Data
Population
8.4m in 2011 (World Bank Data)
Currency
Euro
GNI (Gross National

Income)
US$48,190 in 2011 (World Bank Data)
Internet Users Per 100

People
79.7 in 2011 (World Bank Data)
Mobile Phone
Subscribers Per 100
People
155 in 2011 (World Bank Data)
Doing Business
Ranking
29 out of 185 (Doing Business 2012, World

Bank)
Credit Rating
Standard & Poors credit rating for Austria is

AA+ with a stable outlook (January 2012).
The Austrian Casino Market

Regulator
The Federal Ministry of Finance is the supervision authority for
gambling in Austria.
Lottery games, casinos, amusements with prizes (AWPs)
and poker are regulated under the Gambling Act 1989
(Glcksspielgesetz).
Although the Glcksspielgesetz contains some provisions

regarding non-casino slot machines, state laws regulate them.
Sports betting is not included in the gaming monopoly, and
licences for this form of gambling are covered by the laws in the
individual federal states.
In addition to the existing 12 casino licences, three licences will

be issued on an individual basis for two new casinos in Vienna
and one in the state of Lower Austria. The deadline for the
submission of bids for these casinos expired in June 2013, and
the decision is still pending.
Games for non-cash prizes are not subject to the monopoly,

provided that the amount of the stake does not exceed 1. These
AWPs are currently operated by private operators.
The granting of concessions will bring back stability

and predictability which is essential for a responsible
company. Karl Stoss, chief executive, Casinos Austria.
Austrias Licensed Casino Market
Casinos Austria holds the sole right to conduct casino gambling
and has 12 casinos across Austria in Baden, Bad Gastein,
Bregenz, Graz, Innsbruck, Kitzbhel, Kleinwalsertal, Linz,
Salzburg, Seefeld, Velden and Vienna.
Although six of the 12 licences were to expire at the end of 2012, on
December 20, 2012 the Austrian Ministry of Finance again granted
them to Casinos Austria for 15 years commencing on January 1, 2013.
The Austrian parliament amended the Glcksspielgesetz, the
countrys primary gambling law, in 2008, 2010 and 2011.
These amendments included allowing EU- and EEA-based
casino operators to advertise in Austria with permission from
the Ministry of Finance, and allowing European operators to
participate in the tenders for lottery and casino licences.
Casino tax is calculated on the annual gross gaming revenues

of each casino operation and, in the case of payouts by gaming
machines, the annual gross gaming revenues from gambling
machines in each casino operation, less VAT.
After the amendments to the Glcksspielgesetz, which entered
into force on January 1, 2011, the casino tax moved to a uniform
rate of 30 percent.
Casinos Austria and Austrian Lotteries are major contributors to

society.
The Casinos Austria Group is the second largest taxpayer in
Austria, provides both financial and organisational support to
a wide variety of good causes and sponsors a wide range of
cultural, sports and charity institutions and events.
Casinos Austria is a member of, and proactive contributor to,
the UN Global Compact, Transparency International (Austrian
Chapter) and respACT, Austrias most important CSR promoter.
Although CSR at Casinos Austria means far more than just
responsible gambling, over-compliance with the corresponding
statutory provisions is, of course, also a CSR priority.
Social Responsibility Measures
The responsible gambling goal of Casinos Austria is to minimise
problem gambling and is enforced with the following measures:
1.
2.
3.
4.
Player protection
Regular and lasting training
Responsible advertising (Code of Conduct)
Sponsoring of research activities and cooperation with
counselling and treatment facilities (e.g., Responsible
Gaming Academy since 2004)
5. Quality assurance of measures, programmes and processes
(feedback and reporting system for quality assurance of
screening in accordance with the Austrian Gaming Act.
The tender process for the city package (Stadtpaket), which

contains the existing casinos in six major Austrian cities (Vienna,
Salzburg, Bregenz, Graz, Linz and Innsbruck), was completed in
December 2012. The licences were awarded to Casinos Austria
and are valid from January 1, 2013 for a period of 15 years.
In Austria lottery is subject to a monopoly licence, which has

been held by Austrian Lotteries since 1986. Casinos Austria has
the casino concession and operates the 12 casinos.
20
Taxation
Operators from the EU and the EEA can apply for an Austrian
casino licence.
A decision in the tender process for the licences in the regional

package (Landpaket) was announced in October 2013, and the
licences for the six existing casino venues outside provincial
capitals that are due to expire on December 31, 2015 were again
awarded to Casinos Austria.
A multi-package tender took place in 2012/2013 for the countrys

casino concessions.
The Slovenian casino operator, HIT, contested the Austrian

amended foreign casino advertising rules at the CJEU and, in a July
2012 ruling, the court found that the Austrian casino advertising
rules can be considered proportionate with the laws of the EU.
Poker
The Austrian Gambling Act has regulated poker as a form of
gambling since 2010. Before that poker was also considered to
be part of the monopoly.
Existing poker hall operators could, however, continue to
operate legally until the end of 2012.
In 2012 a new poker room licence was scheduled to be awarded.
However, this process did not take place, leading to legal
upheaval. The offer of online poker is the exclusive right of the
lottery monopoly, Austrian Lotteries.
The wider industrys legal challenges against land-based poker
regulation introduced in 2010 have proven to be successful.
Registration
Under the provisions of Article 25 (1) of the Federal Law on
Games of Chance (Gambling Act) and the valid licences
currently issued in Austria, only adults who have provided
adequate proof of identity (official photo ID) who are not subject
to any form of entry ban can be permitted to enter and gamble
in a casino.
National legislation requires customers to be 18 years of age.
Casinos Austria records and stores the data on the ID provided
for a period of at least five years. If there is any doubt regarding a
guests identity or right to access the casino, they will be denied
entry until the matter has been satisfactorily resolved.
Screening
As a result of the Austrian Constitutional Courts ruling delivered

on June 27, 2013, the land-based poker-related provisions of the
Gambling Act have been lifted and poker can now be operated
under the countrys general trade law, until a new resolution is
decided in parliament.
By monitoring visit frequency and gambling intensity, Casinos

Austria is able to identify any individuals who are potentially at
risk.
Contributions to Society, Good Causes
Casinos Austria carries out credit checks on such individuals in

line with the player protection provisions set out in Article 25 (3)
of the Gambling Act.
Casinos Austria seeks open dialogue with its stakeholders

and enjoys a strong reputation and high level of credibility not
only with regard to traditional CSR issues, such as long-term
respect for the environment and the workforce, but also for its
acknowledgement and acceptance of its particular responsibility
to society and the specific issues associated with the gaming
business.
Credit Checks
If necessary, specially trained members of Casinos Austria staff

then meet with such individuals to discuss the situation and draw
their attention to the risks of gambling and the potential threat
to their subsistence level. They also provide information on
appropriate counselling options and institutions.
21
Entry Restrictions/Operator Bans

If an individual does not have sufficient financial means to
continue gambling, the operator is required by law to either
restrict the frequency of their visits or ban them temporarily or
permanently from entering casino properties.
Among the applicants were Austrian Lotteries, the Swiss

company Lottelo and Bet-at-Home.
Austrian Lotteries won the tender in October 2011 for another 15
years commencing from October 2012.
Entry Restrictions/Self-Exclusion
Electronic lotteries are taxed at a rate of 40 percent of gross

gaming revenues.
Guests also have the option to self-exclude, a process whereby

they can request that their number of visits be restricted or have
themselves totally banned from entering a casino.
Under the terms of the Glcksspielgesetz online companies

targeting Austrian players are liable to pay tax in Austria,
whether they are licensed there or not.
Smoking Ban
According to the Austrian law, there is a general ban on
smoking in public places. However, in the case of hospitality
establishments, smoking can be allowed in certain rooms, which
can be separated from non-smoking areas and must comply
with the additional requirements under the law.
VLTs
Currently, Austrian Lotteries (sterreichische Lotterien
Gesellschaft) holds the sole licence in relation to lotteries, video
lottery terminals (VLTs) and online casino games. The company
was granted a new licence for another 15 years commencing on
October 1, 2012, following an EU-wide licensing process.
In 2007 Casinos Austria purchased a majority share in Austrian
Lotteries.
Remote Gambling
Online casino-style games are part of the lottery monopoly.
Companies not licensed in Austria but targeting Austrian

players are liable to a 16 percent turnover tax on the games they
offer, with the exception of betting games, and their offers are
considered to be illegal.
Betting companies licensed in Austria are liable to a 2 percent
turnover tax. Some states such as Burgenland, Vienna and
Lower Austria have additional charges on bets and winnings.
Companies not licensed in Austria but targeting Austrian players
are also liable to a tax rate of 5 percent on turnover.
The minimum age for online gambling in Austria is 18 years.
BELGIUM
Belgiums nine casinos have experienced slowly declining

or flat revenues in the past three years, with visitation in
2012 close to the figure achieved in 2010.
Oostende
Knokke-Heist
Spend on slot machines in casinos has grown by 7 percent

Blankenberge
in the past three years but table game win has fallen by
Middelkerke
nearly 9 percent.
The nine Belgian casinos paid 39.75m in gaming taxes in
2012, a decrease on the 42.04m paid in 2011.
Brussels
Namur
A number of factors account for the stalled revenues,

from the smoking ban introduced in 2011 to the growth
of online gambling. The national lottery, with increased
product offerings, saw its turnover rebound sharply
in 2011, with turnover at 1.2bn, up 9 percent from the
previous year.
Belgium, more than any other member state, has become
the battleground for the discussions over restrictions in
online licensing that favour incumbent licensed operators.
Only those businesses with a land-based operation
have the right to extend their offerings to online, under
Belgiums gambling laws.
In October 2012, the European Commission sent letters
to 20 member states requesting information on the
countries which are subject to infringement cases or
complaints for breaching EU law. Belgium received one
of these letters which questioned the justification for the
requirement for an online licence to be tied to a landbased licence.
Chaudfontaine
Spa
Dinant
Blankenberge
Brussels
Chaudfontaine
Dinant
Knokke-Heist
Middelkerke
Namur
Oostende
Spa
In 2012, Austrian Lotteries online gambling website, win2day.at,

remained its best performing product.
For betting, there are licences available to private operators
under the provision of state laws.
In June 2011 the Ministry of Finance launched the tender process
for the sole lottery licence, which included, in addition to online
lotteries, the licence for offering casino-style games online.
22
23

Market Data
Population
Currency
Euro
GNI (Gross National

Income)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
AA, Fitch, March 6, 2013
The Belgian Casino Market

Regulator
The Belgian Gaming Act of May 7, 1999 created a gaming
supervisory body, the Belgian Gaming Commission (BGC), which
is responsible for issuing licences, both online and offline, and
approving the types of machines to be used in Belgian casinos,
arcades and other gambling establishments. It also conducts
background checks on applicants and verifies continued
compliance with gaming law.
According to the 1999 Gaming Act, an operator which has been

granted a licence cannot sell it to another operator.
Belgiums casinos exist alongside a thriving lottery monopoly.
The Loterie Nationale pays a fee for its monopoly of 95m.
40m was added to this fee in 2012. In 2011, the Loterie Nationale
paid 225.3m in subsidies to the state, according to its annual
report.
Various complaints are also currently pending before the

European Commission regarding the regulatory framework for
online gambling which has been in place in Belgium since 2011.
The Belgian Constitutional Court rendered a verdict on July 14, 2011 in
which it dismissed claims of violation of the constitutional principles
of equality and non-discrimination and refused to raise a preliminary
issue at the Court of Justice of the European Union (CJEU).
Belgiums Licensed Casino Market
The number of Class I casinos is limited to nine in Belgium and
the number of arcades (Class II) is limited to 180.
24
Since July 15, 2011, exclusions at the request of a third party have
been made possible. Social workers and other interested parties
can apply to the Gaming Commission to limit the access of a
person believed to be a problem gambler to a casino or slot hall.
The BGC issues leaflets regarding player protection and
discusses the issue of player protection with all members of staff
during the session staff members have to attend to obtain their
gaming licence. The display of these on the player protection
leaflets is mandatory for all casinos.
Smoking Ban
A general ban on smoking has been in force in the hospitality
industry since July 1, 2011. Smoking rooms equipped with smoke
extraction systems are permitted, subject to further conditions.
Problem Gambling Prevention Policies
Taxation
Belgiums casinos pay tax on their gross gaming revenues.
For baccarat and similar games, the casinos pay 4.8 percent of
house win.
In February 2012, new types of licences for remote gambling

were introduced. These licences, called A+, B+ and F1+, entitle
the holder to expand its land-based products to the internet,
regulating online casino gaming, online poker and online
betting. A total of nine Class I casino licences are available and
180 Class II arcade licences.
Belgian authorities enacted the law despite the detailed opinion,

arguing that their approach is compliant with EU law as these
measures aim to protect Belgian consumers.
When excluded from a casino, a player can ask the Gaming

Commission to be able to re-enter the casino. If the commission
agrees to this, a three-month period applies before the player
can return to the casino.
ATMs are prohibited in Class I, II, III, and IV establishments. The

provision of credit to players is prohibited. Credit may not be
used for the settlement of a loss or for the payment of a stake.
The Belgian Gaming Act lists nine different types of operating

licences including A class licences for Class I casinos, and
Licence B for Class II arcades.
Before the Belgian Gaming Act was modified to regulate online

gambling, the European Commission issued a detailed opinion
on the draft pointing at several concerns regarding the draft law.
Among these concerns was the requirement according to which
online licences are tied to land-based licences.
Each customer entering a casino or arcade must be checked

against the EPIS-database, prior to entering. EPIS is not just
a self-exclusion system. It also includes most of the persons
legally excluded such as judicial officers, bailiffs, police officers,
etc. (Article 54, para 2 of the Gaming Act).
For gaming machines and slots the tax rates are tiered according
to revenue:

Contributions to society are made on a voluntary basis.
Contributions to charitable and other good causes are
determined by each casino individually.
Access to Class I casino gambling and Class II machine
gambliing is restricted to people of 21 years of age or over, while
betting shops are open to those who are not minors (at least 18
years of age).
Age restrictions for online games mirror those that apply to
land-based games, so all online games are prohibited to players
under 21 years old, except for betting which is prohibited to
players under 18 years old.
A player can ask for self-exclusion through the BGC. The player
is then registered in Belgiums EPIS-database (Excluded Persons
Information System).
0.01 to 1,200,000 revenues: 20 percent.

1,200,000.01 to 2,450,000: 25 percent.
2,450,000.01 to 3,700,000 revenues: 30 percent.
Any revenues above 12,350,000 are taxed at 50 percent.
A controversial report on youth gambling prevalence in the

country in 2009, indicated that a quarter of all minors in Belgium
aged 10-17 admitted to gambling, and helped jump-start
the reform of online gambling regulation in Belgium as the
government answered calls to make access to gambling more
difficult for minors.
Presenting his draft bill to the Belgian media in March 2009,
secretary of state Carl Devlies pointed to the statistics on youth
gambling as a reason for adopting a new gaming legislative
regime in the country.
The same games allowed in land-based operations are allowed
online. Out of the nine casinos, seven casinos have so far
introduced online offerings. Three casinos launched their own
brand of online casino:

Casino Grand Brussels / Viage as win2day.be

Casino Spa as www.casino777.be
Casino Dinant as www.partouche.be
Four other casinos entered into partnerships and / or joint

ventures with the already existing major online players on the
market:

Casino Blankenberge with Unibet as Unibet.be

Casino Oostende and Bwin.Party as bwin.be
Casino Namur and Pokerstars as www.pokerstars.be
Casino Knokke and Williams Interactive as www.
jackpotparty.be
The BGC has always affirmed that the Belgian law is compliant
with EU law, still, observers from both public and private
gaming entities are awaiting the European Commissions next
statements regarding its infringement proceedings.
Belgiums Gambling Commission enforces its online licensing
via payment level and ISP blocking and publishes a blacklist on
its own website. The BGC began taking enforcement measures
against unlicensed websites offering their services in the country
in February 2012, and entered into an agreement with a number
of internet service providers (ISPs) to block websites on the
blacklist.
Online gambling tax is set at the regional level in Belgium. Each
of the countrys three regions (Flanders, Wallonia and BrusselsCapital) have adopted an online gambling tax at 11 percent of
gross gaming revenues.
For other casino games, revenues up to 865,000 are taxed at

33 percent, while revenues exceeding that figure are taxed at 44
percent.
Remote Gambling
The Belgian Gaming Commission has a been contacted
by many players indicating that, with the blacklist, there
is more clarity about the legal and illegal offer than in the
past. Peter Naesens, legal advisor to the Belgian Gaming
Commission.
Belgiums Gaming Law decrees that only land-based casinos
or arcades, which have already obtained a licence for their
land-based operations from the BGC, can apply for a licence to
operate an online website.
25
CZECH REPUBLIC
Total revenues in the Czech Republics casinos fell by 7.65

percent in 2012 when compared to the same period a year
before, but the market has rebounded from the worst of
its recessionary levels, and revenue now stands higher
than its 2010 level.
There are 185 casinos in the Czech Republic, 8
percent fewer than the 199 that existed in 2010.
Over the same period jobs created by the countrys
casinos fell from 3,165 to 2,850.
The Czech Republics municipalities recently gained much
stronger powers to limit VLT and slot machine numbers
and operating hours in their own territories.
The Czech Republic has numerous small

casinos, encouraged by ownership rules
which allow foreign shareholders to invest.
27

Market Data
Population
Currency
Czech koruna (CZK)
GNI (Gross National

Income)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
A+ with a stable outlook, Fitch Ratings,

December 2012
The Czech Casino Market

Regulator
The Czech Republics Ministry of Finance carries out the
regulation and licensing of casino games, slot machines and
lotteries. Additional supervision is provided by the local financial
offices, with local municipalities also involved in the licensing
process.
The current Czech regulatory framework, based on gaming laws
from the early 1990s, is largely outdated following the vigorous
growth of the gambling sector.
Although the Czech Republic notified a new draft gambling act
to the European Commission in August 2012, the controversial
restrictions imposed on foreign remote gambling operators
ensured a critical response from Brussels in November 2012 and
none of the measures have yet been implemented.
Casinos are unique in the Czech gaming market in that they do

not need to follow the same complex ownership requirements as
other providers of gaming services, which prohibit Czech entities
with foreign shareholders from obtaining a gaming licence.
Casinos may be operated by a Czech entity with foreign
investment, if the Ministry of Finance grants this exception, and
it is this flexibility with regard to foreign investment that has
helped encouraged growth in the numbers of casinos operating
in the Czech Republic.
According to Ministry of Finance data, in 2010 there were 136
operators with valid gambling licences, which included both
domestic and international companies with financial stakes in
Czech land-based casinos.
Compared with the rest of Europe, the Czech Republic has taken
a relatively liberal regulatory approach to gambling, fostering an
influx of small casinos across the country in the 20 years since
the Velvet Revolution of 1989.
Major players include Casinos Austria International, which operates
through its subsidiary Czech Casinos; Novomatic, which established
its presence through subsidiary company European Data Project
(EDP); and American Chance Casinos (ACC), a European subsidiary
of publicly-traded US company Trans World Corporation.
28
Amendments, which came into force on January 1, 2012, changed

the system of charitable contributions, which had previously
been directed towards sport, cultural, healthy and general
charitable activities. From 2012 onwards the offices of the
Ministry of Finance have redistributed this part of the gaming tax.
National legislation requires all customers to be 18 years of age.
The Ministry of Finance sets out detailed terms and conditions
for the operation of each casino licence. Changes in the gaming
mix (in terms of types of games offered) must be approved
by the Ministry of Finance which has 30 days to do so after
notification.
Smoking Ban
There is no smoking ban in place in Czech casinos.
There are no legal requirements for player protection in the
Czech Republic, although most Czech casinos follow the
guidelines of the Social Responsibility Programme overseen by
the Czech Institute for Addiction Research.
City councils, as relevant authorities in the licensing process,
frequently demand evidence that prospective licensees will behave
responsibly.
Taxation
A caretaker government, appointed by the President, has since

failed to win the confidence of the parliament. Further elections
are scheduled to be held on October 25 and 26, 2013.
Czech Republics Licensed Casino Market
Gaming tax represents a significant part of the tax income

received by local authorities in the Czech Republic.
The Ministry of Finance, based on the operators application,

issues licences for games taking place in Czech currency and /
or all other requested currencies. The exchange office is usually
a subsidiary casino activity in order to exchange currencies to
the gaming currency, but the activity of the exchange office is
regulated by the Czech National Bank.
In March 2013, the government tasked the ministry with

preparing an amended draft by June 30, 2013. Still, the new draft
law has not yet surfaced, as a result of the political turmoil that
hastened the fall of the government during the summer.
In July 2013, the caretaker government asked the European

Commission to permit Czech lawmakers to send a new EU-law
compliant draft gambling law to the commission by the end of
2014, indicating implementation will not take place until 2015 at
the earliest.
The present gaming tax structure has applied since January 2012, and
is defined in the Lottery Law.
Poker
Until 2011 gambling law amendments came into effect, card
games could legally only be played in licensed casinos, but this
restriction was widely overlooked, by a wide group of card clubs
constituted as so-called civic associations.
Estimates on the number of poker players vary wildly between
10,000 and 200,000, but, in the absence of a law expressly
regulating poker outside casinos, no taxes or fees are payable on
the fees retained by card clubs.
Under amendments made on January 1, 2012, card games are now
permitted on the internet; however, those companies holding
sports-betting licences have been reluctant to adopt online poker.
The current tax for casinos, slot machines and VLTs is calculated at
20 percent of gross gaming revenues (GGR). There is also a fee of
CZK55 per gambling machine (VLT or slot machine) per day.
Gross gaming revenues are not subject to VAT in the Czech
Republic.
Since 2012 casino VLT and slot machine operators have been
fully subject to the countrys corporate tax regime, a change
from the situation that existed until the end of 2011 whereby
GGR-related income had not been subject to corporate taxes.
VLTs and Slot Machines
The Czech Republics gambling market remains dominated
by VLTs. 2012 data from the Ministry of Finance showed VLTs
accounting for 49.4 percent of the market revenues, with
traditional slot machines holding a 13.9 percent revenue share
(of which 5.3 percent was attributable to casinos) and casinos
themselves held 5.2 percent of the market.
A consensus has been building for changes with regard to the
proliferation of VLTs and the compulsory contributions made by
operators to good causes.
On June 21, 2011 the lower house of the Czech parliament passed
a bill that extended the powers of municipalities to regulate
gambling in their territory, with a three-year transition period.
Seeking faster results, Klatovy municipality made a complaint to
the Constitutional Court in June 2012 that enabled municipalities
across the country to limit the number of VLTs on their territory
with immediate effect.
Remote Gambling
With the exception of sports betting and poker, online gambling
is not regulated in the Czech Republic; however, many foreign
online operators offer casino games, which are widely advertised
in the Czech language.
Since January 1, 2012 it has been illegal to advertise games of
chance that have not been authorised by the state regulator.
At the same time local restrictions by city authorities can also
limit the advertising of permitted games.
In 2008 the Czech government licensed five domestic betting
operators, SAZKA, Synot Tip, Chance, Tipsport and Fortuna,
to offer online games from the beginning of 2009. These
licence awards have since become the focus of anti-corruption
investigations.
Three more licences were granted in September 2009 and, as of
June 2012, there were nine licensees.
Although the Czech Republic notified a new draft gambling act to
the European Commission in August 2012, due to the restrictions it
would have imposed on foreign remote gambling operators, the
draft received criticism from the European Commission at the end
of its standstill period and has not progressed.
Similar measures that would impose a duty on internet service
providers (ISPs) to block advertising and access to games offered
by unlicensed operators have also stalled in the face of popular
protests.
29
Czech-based licensed operators have indicated that they would

welcome regulation which would extend online gambling to
other products including casino-style games.
Foreign operators without any Czech licence have a 100
percent market share (of online casino and poker). The
ideal solution for both the Czech state and customers is
to open up the internet lottery business to more products
and to create clear, transparent operating rules, said
Zdenk Brzdil, CEO of Chance.
DENMARK
Denmarks six casinos saw their gross gaming revenues

grow by 3.6 percent, from 55m to a total of 57m,
between 2011 and 2012.
In 2012 revenues from table games remained flat at 31m,
while slots win swelled by 7.1 percent and the gaming tax
paid to the state increased 4 percent to 26m.
A new regulatory regime for gambling came into force in
Denmark on January 1, 2012, putting in place a licensing
system for sports betting and online casino games
including poker.
Casino Royal and the Danish Slot Machine Association
believe the taxation arrangements whereby online
operators pay tax at 20 percent compared to the 75
percent levied on land-based operators are illegal under
European law, and have pursued a legal case against this.
A decision by the European Commission, which found
that the differential tax rate was justifiable to encourage
online operators to move within the regulated market,
and combat illegal offerings, has been appealed to the
European Courts.
The online division of the former Danish monopoly,
Danske Licens Spil, still dominates the licensed online
market in Denmark, holding what is believed to be a more
than 60 percent market share.
30
Casino Aalborg
Royal Casino (Aarhus)

Casino Munkebjerg Vejle
Casino Marienlyst (Helsingr)
Casino Odense
Casino Copenhagen
Casino Aalborg
Royal Casino (Aarhus)
Casino Copenhagen
Casino Marienlyst (Helsingr)
Casino Odense
Casino Vejle (Casino Munkebjerg Vejle)
31

Market Data
Population
5.571m (World Bank Data, 2011)
Currency
Danish krone (DKK)
GNI (Gross National

Income)
$60,160 (World Bank Data, 2011)

People
90.0 (World Bank Data, 2011)
Mobile Phone
Subscribers Per 100
People
128 (World Bank Data, 2011)
Doing Business
Ranking

Bank)
Credit Rating
AAA (Standard & Poors)
The Danish Casino Market
Denmarks Licensed Casino Market
Regulator
There are currently six casinos in Denmark and one licensed onboard ship casino.
Denmarks gambling regulator is the Danish Gambling Authority.

Land-based casino licences are granted for a period of up to ten
years.
The Act on Gambling of 2010 partially liberalised the Danish
gambling market, which officially opened on January 1, 2012.
As of July 2013, 53 licences have been granted to 40 operators.
Danske Spil still holds a monopoly licence to provide lottery
games.
Casinos in Denmark are regulated by the Act on Gambling and

the Order on land-based casinos.
According to the Act on Gambling, casinos may offer the
following games: roulette, baccarat, punto banco, black jack,
poker and gaming machines offering cash winnings.

In Denmark national legislation requires all customers, both
online and in land-based properties, to be 18 years of age.
A smoking ban has been in force in public areas in Denmark
since 2007, but smoking is allowed in smoking cubicles/
separate smoking areas.
Denmarks casinos are subject to stringent requirements relating
to the registration of customers, including video registration, and
for the storing of data.
Each guest must provide identification on request and every
casino must record information about each arriving guests
name, address, and date of birth, nationality and an indication of
arrival time. The casino must store this data for five years.
Casino staff are subject to additional requirements and may not
participate in games at the property.
The Danish Gambling Authority is in charge of supervising the
machine market as a whole.
For online gambling, a system named ROFUS Register of
Voluntary Excluded Players has been established. Players can
directly register themselves on the system and once registered
they cannot cancel it.
Online operators are obliged to verify whether a player is
registered on this self-exclusion system. Temporary exclusions
are also possible and cannot be for less than one month or
above six months. Players can also choose a shorter break of 24
hours, dubbed the cooling-off period.
The executive order on land-based casinos sets out restrictions

on the size of the stakes for each game.
A player may not bet less than DKK5 or more than DKK50,000,
except for games on gaming machines where a player may not
bet less than DKK1 or more than DKK20 per line/chance.
A 2006 study entitled The Prevalence of Problematic

Gambling Behaviour a Scandinavian Comparison
surveyed more than 8,000 Danish residents.
Each casino has the obligation to set minimum and maximum

bets for each game, which must be posted at each game table.
NODS identified three types of problem gambling

prevalence: pathological, problematic and at-risk
gamblers.
In 2012 further requirements were added regarding exchange

of gaming tokens and use of cash in the casinos, as well as
requirements on gaming technology equipment, the tronc,
annual accounts and audit and control issues.
Poker
Many casinos in Denmark offer additional table games as well as
variants of poker.
According to the Act on Public Gambling in Tournaments, a
licence to organise public gambling in tournaments can be
obtained by application to the Danish Gambling Authority. The
licence is restricted to one tournament a week with limited buyin (40), number of players and prize pool.
The study found that 3.9 percent of the Danish population

either has or had at one stage a gambling problem, while
2.3 percent were identified as having had a problem in the
past year.
The study found that both Sweden and Norway had higher
rates of problem gambling (in all three categories of
pathological, problematic and at-risk) than Denmark.
Taxation
Casinos are subject to a tax of 45 percent of revenues up to
DKK4m and 75 percent for any portion of revenues above this
amount.
A new regulatory regime for online gambling came into force in

Denmark on January 1, 2012, putting in place a licensing system
for sports betting and online casino games including poker.
The new gambling law partially dismantled Danske Spils
exclusive rights regime that applied to sports betting, although
the state-controlled company maintains its monopoly over
national lottery products and bingo.
Following a complaint from a land-based casino and slot
machine operators, the European Commission opened an indepth investigation regarding the taxation system applied to
online and retail gambling in this new piece of legislation, which
delayed the opening of the market in Denmark.
In a decision concluded on September 20, 2011 the commission
found that the Danish government was, in effect, providing
online operators with state aid by allowing them to be taxed
at 20 percent of gaming revenues, in comparison to a 45/75
percent rate for the land-based sector.
However, SKAT, the Danish tax ministry, was successfully able
to argue that rate was necessary to ensure that online operators
would move operations within the regulated market and combat
illegal offerings.
The case has been appealed before the Court of Justice of the
European Union. A decision from the highest European court is
expected sometime in the next two years.
In 2011, Danske Automat Spil merged with the company Elite
Gaming A/S, and, subsequent to the merger, bought the
remaining 50.1 percent of the shares in 2012. State-controlled
Danske Spil now conducts its gaming machine operations
through its wholly-owned subsidiary, Elite Gaming.
There are also a significant number of private operators in the
Danish slot machine market, most of whom are members of the
industry association Danske Automat Brancheforening (DAB)
and slot machines outside a casino, typically AWPs, in Denmark
are also governed by the Act on Gambling.
Denmarks casinos have contributed financially to some of the

treatment centres for gambling addicts.
32
33
ESTONIA
As of 2010, slot machine operators pay the following taxes:
Restaurants:
41 percent of monthly gross gaming revenues (GGR) up to
DKK30,000.
71 percent for the portion of monthly GGR above
DKK30,000.
Arcades:
41 percent of monthly GGR up to DKK250,000.
71 percent of GGR over DKK250,000.
The slot machine industry here in Denmark will be
smaller as a result of the new online market, there is no
doubt about it. Knud Larsen, director of Dansk Automat
Brancheforening (DAB).
Remote Gambling
Along with Italy, Finland and Norway, Denmark is one of a small
group of countries in Europe where online casinos have been
licensed and legalised.
As of July 2013, 53 online licences had been granted to 40
operators, but the online arm of the former monopoly Danske
Licens Spil is still the most significant online and offline operator
in Denmark for sports betting and online poker and casino games.
Danske Licens Spils GGR grew 12 percent in the first six months
of 2013, amounting to DKK678m (70m) and GGR for its in-play
betting product, Oddset Live, swelled by more than 50 percent
34
compared with the same period a year before. GGR for mobile
betting tripled.
Currently a tax of 20 percent of GGR applies to online operators
and a much higher tax rate of 75 percent applies to landbased operators, a tax differential which has been the cause of
significant dispute between operators and the government.
The Danish Gambling Authority is currently in the process of
reviewing the Act on Gambling, with only cosmetic changes to
the taxation system applying to online operators expected at
this stage.
720,000 players visited Estonias casinos in 2012, 20,000,

or 2.9 percent, more than the year before. Total casino
revenues grew 8.3 percent to 52m, as slots saw growth
of 9.5 percent but table revenues remained flat.
Arcades have the same status as casinos in Estonia and,
by May 2013, there were 57 arcade/casino premises in the
country, a steep decline from the 171 premises recorded in
November 2008.
After a surge in both slot machines and gambling
premises between 2005 and 2007, since the Gambling
Act 2009 was passed there has been a dramatic decline in
slot machine numbers, gambling table numbers and the
number of gambling premises.
Since January 1, 2010 casinos have been required to have
at least 40 slot machines and / or five gambling tables.
Estonian-listed Olympic Entertainment estimated it had
attained a 56 percent share of the Estonian land-based
gaming market for the first six months of 2013, a 2 percent
gain year-on-year.
There are 57 arcade and casino premises

across Estonia, a steep decline from the 171
premises recorded in November 2008.
Remote gambling was regulated in Estonia from the

beginning of 2010 and, following recent approvals, eight
operators are licensed in the country. There is a blacklist
of approximately 831 unlicensed websites.
35

Market Data
Population
Currency
Euro
GNI (Gross National

Income)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
A+ from Fitch Ratings with a stable outlook,

June 2012
The Estonian Casino Market

Economic Situation
Before the global economic downturn Estonias economy was
growing at astonishing rates. In the period between 2003 and
2007 gross national income (GNI) grew from US$5,820 to
US$13,380. But by 2012 GNI had only reached US$15,830, a 3.7
percent increase compared with the previous year.
Estonian casinos were severely affected by the global financial
crisis that began in 2008. Olympic Entertainment posted a
first-quarter loss of 55.9 percent in Estonia in 2009, compared
with the first quarter of 2008. Olympic also closed seven of its
casinos during that quarter.
The Ritzio Group company Cityclub O (operator of the CityCasino
brand) also announced its bankruptcy in August 2009.
In addition to the share capital requirement of 1m, casino

operators must pay fees of 47,933.73 for a review of an activity
licence and 3,195.58 for a review of an operating permit.

Those under the age of 21 are not allowed to enter a casino or
work directly with games of chance in casinos.
A player protection programme has been established according
to the law and includes a self-exclusion programme, for which
a database of excluded people is operated and maintained
according to the statutes of the Tax and Customs Board and the
Ministry of Finance.
Players can place themselves on the list and become excluded
from casinos for a period of six months to three years.
Information included on the database includes the players
name, personal ID code, or, if not present, date of birth and a photo.
Estonia has thoroughly modernised its gambling regulation with

the Gambling Act of 2009.
It is an obligation for operators to establish an adequate system

to ensure that persons on the list are not permitted to play
games of chance.
Organisers of games of chance are prohibited from processing
the data on the list for the purposes of direct marketing, or to
transfer the data to third parties.
It remains difficult to accurately quantify the number of casinos

in Estonia because legislation makes no distinction between a
slot hall and a casino, both being games of chance operators.
In some instances slot halls have the term casino in their title.
Smoking has been banned in Estonia since 2005 in indoor public

places, with the ban being extended in 2007. The law, however,
allows for the establishment of designated smoking areas.
Increasingly popular in Estonia, Poker tournaments have been

regulated since 2009 under the category of tournaments of chance.
Games of chance tournaments are taxed at a rate of 5 percent of
participation fees.
Casino operators (public or private limited companies) are required

to have share capital of at least 1m and hold both an activity
licence and an operating permit. Although the activity licence is for
an unspecified term, operating permits are valid for 20 years.

Funds collected through gambling tax payments go towards the
following areas of the state budget:

Slot machines are the most prevalent form of gambling activity
in Estonia. With the introduction of the new Gambling Act, the
number of slot machines has fallen sharply from approximately
5,200 machines at the beginning of 2008 to 2,067 as of May
2013.
Gaming machines are taxed at a flat rate of 447.38 per machine
per month. If a gambling machine allows several players to
participate, the tax is calculated based on the number of playing
positions.
Remote Gambling
Olympic Entertainment was awarded an online gambling licence
in January 2010, and launched its online casino and poker room
Olympic-Online.com on February 10, 2010, and rebranded it to
OlyBet.com on August 1, 2013. A second licence was awarded to
Alands Penningautomatforening (PAF) in April 2010.
For operators offering online gambling, players would be

required to set weekly or monthly limits on their losses.
Limits can modified, but only after 72 hours.
Estonias gambling market consists of gambling machines,

casino operators, skill games, sports betting and a state-owned
lottery operator. In the past the market belonged largely to
gaming machines, but the number of machines has dropped
drastically since the introduction of legislative changes in 2009.
Gambling regulation falls under the remit of the Ministry of

Finance and the Tax and Customs Board, and casino gambling is
subject to the provisions of the Gambling Act under the general
term games of chance.
Gambling tables are taxed at a flat rate of 1,278.23 per table

per month.
In June 2013 the Ministry of Finance submitted draft amendments

to the Gambling Act which would introduce additional player
protection requirements for both online gambling and lottery
games.
The act was introduced to better regulate an industry that had

grown into many small, widely dispersed, gambling locations.
The government sought to decrease the demand for gambling
through industry consolidation by raising minimum machine
numbers and giving local authorities more power to control
where gambling locations can be placed.
Poker
Taxation
Subsequently licences were awarded to Nordic Gaming

Group subsidiary Triobet and PokerStars (REEL Estonia Ltd) in
2010. Eight entities are now licensed in Estonia to offer online
gambling.
Estonias Licensed Casino Market
Regulator
Of the total proceeds, the Cultural Endowment of Estonia

receives 46 percent
2. The Council of Gambling Tax receives 37.4 percent
3. The Ministry of Internal Affairs is allocated 12.7 percent
4. The Estonian Red Cross receives 3.9 percent
Since January 1, 2010 casinos have been required to include at

least 40 slot machines and / or five gambling tables.
The legislative update also allowed Estonia the opportunity

to regulate previously unregulated types of gambling, and
particularly online gambling. Legislation relating to online
gambling came into effect at the beginning of 2010.
36
1.
The draft foresees June 1, 2014 for the requirements relating

to online gambling and January 1, 2016 for the identification
obligation for lottery operators to enter into force.
Smoking Ban

Estonias 2009 Gambling Act contains a number of general
requirements for gambling organisers obliging them to:

Display rules of play.

Display clear warnings regarding the addictiveness of gambling.
Conduct staff training on gambling addiction awareness
Put in place fraud prevention measures.
Restrict access to those not entitled to enter/participate,
such as those under 21 years of age for games of chance
and 16 years of age for lotteries.
37
FINLAND
Raha-automaattiyhdistys (RAY), the Finnish slot machine

association, is the only operator authorised to operate
casino games and casino activities in Finland. There is
currently just one casino in Finland, the Casino Helsinki;
although in 2012 approval was granted to launch a second
land-based casino in Vaalimaa in the eastern part of
Finland bordering Russia.
Finland has a gambling sector built on a foundation of
exclusive rights, with three state-owned monopolies
effectively controlling the market over lotteries and
betting (Veikkaus); slot machines and casino (RAY); and
horse race betting (Fintoto). These rights extend to the
offer of online games.
RAYs online casino games have proved far more popular
than its poker network, which has struggled to compete
with foreign websites since it launched at the end of 2010.
Collectively, Finlands gambling monopolies raise 1.7bn
every year to finance social activities.
Finlands exclusive rights system resulted in European
Commission infringement proceedings and, in answer to
the commissions concerns, a reform process which began
in 2007 and ended with the countrys three mainland
monopolies being written into law in 2012.
Casino Helsinki
Casino Helsinki, with 140 full-time

employees and 42 part-time staff, is
located in the centre of the Nordic nations
capital.
The land islands, a Swedish-speaking autonomous

region of Finland, have expressed a wish for their own
licensed operator, Paf, to be included in those operators
which can legally market themselves on mainland
Finland, but no decision has yet been made.
39
Market Data
Population
5.41m (World Bank Data 2012)
Currency
Euro
GNI (Gross National

Income)
$46,940 (World Bank 2012)

People
91 (World Bank 2012)
Mobile Phone
Subscribers
9,320,000 (World Bank 2012)
Doing Business
Ranking

Bank)
Credit Rating
AAA (Fitch 2012)
The Finnish Casino Market

Net gaming revenues at the Casino Helsinki have fluctuated
in recent years. In 2008, net game revenues reached a peak at
32.5m but fell away sharply by nearly 5m in 2009 and have
levelled off at around a figure of 25m during the last three
years.
Just over 6km away in Vaalimaa, RAY has received governmental

authorisation to develop a second casino near the Russian
border, less than 200 kilometres from St. Petersburg.
The casino is expected to be completed during Summer 2015.
The Vaalimaa casinos location would make it the closest legal
form of casino gambling to St. Petersburg.
A smoking ban is in place in Finland. Smoking-permitted rooms

are allowed, but they cannot offer gaming.

Casino Helsinki uses environmentally-friendly Ekoenergia
energy, which is certified by the Finnish Association for Nature
Conservation. Casino Helsinki also handles the recycling of
waste from its property.
The profits from RAYs games are used for promoting health
and social welfare in Finland. Funding is annually distributed
to various health and social welfare organisations based on
applications submitted.
The fund allocation is guided by policies created by RAYs board
of directors and a result agreement prepared with the Ministry of
Social Affairs and Health.
Nearly 900 organisations receive funding each year.
In 2012 Finlands coalition government indicated that from 2013
a portion of RAYs profits would be siphoned into state coffers
to be spent by the social and health care ministry, pointing to
around 60m that had been left unspent in the previous year.
Under the budget proposals, the government would extend its
control over where grants are allocated by collecting 10m in
2013, rising to 20m in 2014 and 30m from 2015 onwards.

Player Protection
In its legislation, the Finnish government has traditionally put
a great deal of emphasis on addiction prevention and player
protection.
Following the 2011 reforms it has backed its monopoly
framework, insisting gambling not be considered a normal
economic activity.
Regulator
With a population of 5.4m, the Finnish propensity to play
lotteries and slot machines is high, with slot usage in the nation
among the highest in the world.
RAY, the casino and slot machine operator, generated net
gaming revenues (after lottery duty) of 682.3m in 2012, of
which 515.3m came from slot machines spread around the
country.
According to RAY, Finns spent an average of 61 per resident on
slot machines for the first six months of 2013, a marginal rise of
0.50.
In Virolahti, located near the border of Russia, approximately
155 was spent per resident on games, making it the most
popular area for slot machines in the country. RAY officials
attributed the top position to the fact the municipality has a busy
border crossing which sees an influx of Russian visitors.
40
The regulatory authorities charged with the supervision of

gambling in Finland are the Ministry of Internal Affairs and the
Gambling Administration of the National Police Board.
During 2012 the regulator enabled a number of significant
changes to the land-based casino market:

Approval for a second land-based casino in Vaalimaa

(RAY), near the Russian border.
The passage of a new degree raising the maximum
permitted number of slots and table games in land-based
casinos.
10m was mandated as the maximum permitted win at a
land-based casino.
The scale of permitted return to player (RTP) was defined
for the first time within a range of maximum to minimum
RTP.
Finland has put into place player-protection measures such as

maximum wagers, self-exclusion measures and restrictions to
operating hours. Customers of a minimum age limit of 18 years
all need to be registered when they enter a casino facility.
Online Player Protection
To play online, before playing, the players name, social security
number, age and domicile are checked by the Finnish gambling
corporations.
To be allowed to play, customers need to:

Be at least 18 years of age.

Have a Finnish bank account.
Have a Finnish social security number.
Have a permanent address in mainland Finland.
Finland forbids any free games or play-money games before

players are registered, and customers are only allowed one account.
The information that players provide is then checked against
the population information system (PIS), which provides up-todate and real-time data for the National Public Register. Selfexclusion measures and session timers are in place.
Games in which players play each other, including poker, have

no daily cap, but there is a maximum limit of 5,000 on all
gambling accounts and customers cannot put more funds into
their account between 12am and 6am.
As part of the registration process for online gambling, players
need to set daily and monthly loss limits. These limits will apply
to all types of gambling and lotteries at www.ray.fi.
There are maximum daily loss limits of 500 on online slot
machines and on those categorised as table games.
In a 2011 report by Pelihaitat, a Finnish support organisation for
gambling, it was found that approximately 2.7 percent of 15-74
year-old Finns could be classified as problem gamblers (sogs
points 5+) or as having problems controlling their gambling
(sogs 3-4 points.) The 2007 figure was 3.1 percent.
Critics continue to claim that the Finnish framework violates
European law and that the monopolistic nature of the reform
proposals only protected the interests of the government.
However, on the core issue of reducing problem gambling rates,
a Finnish advisor to the Ministry of Interior presented to the
European Parliaments Committee on Market and Consumer
Protection in March 2013 that, according to prevalence surveys,
harmful effects of gambling have been decreasing and the
amount of money used for gambling among problem gamblers
has been decreasing.
Taxation
12 percent of RAYs gross profit (defined as gross gambling
revenue) is returned to the government as taxes.

Raha-automaattiyhdistys (RAY) is the sole authorised operator
of gaming machines in Finland. There are approximately 20,000
low-stake and low-win slot machines operating under the RAY
monopoly in Finland, with very little incidence of unlicensed
machine operation.
The licensed machines are mainly manufactured by RAY with 1/
2 maximum stakes and maximum winnings of approximately.
100 in business premises.
Finland is one of the countries in the world that plays most on
slot machines, with 16 percent of the adult population saying
they have played in the last week.
According to research conducted by Finnish slot monopoly
RAY, 36 percent of people questioned said they have played
in the last year (2012). By comparison, on the same research
methodology, neighbouring Sweden recorded 14 percent having
played in the previous year and just 2 percent having played in
the previous week.
Slot machines are operated in such a way that RAY is
the sole operator and all the money goes to good causes
and everybody knows this. They are very well accepted
compared to any other country, said Anssi Airas, market
intelligence manager at RAY.
41
Slot machine gaming has been rising in popularity in Finland,

with Finns spending an average 122 on slot machines in 2011, an
increase of 7 from 2010.
Remote Gambling
Finland was an early adopter of online gambling with the
introduction of its distribution channel in 1996 and Veikkaus
being given a licence under the Lottery Act to operate games on
the internet. Along with this, Fintoto commenced its totalisator
operations on the internet in 2001.
Finnish law means that the internet is merely another distribution
channel, not a separate form of gambling.
In Finland the concept of License PLUS has been embraced,
meaning land-based operators are allowed to extend their
product offering online, to a so-called bricks and clicks model.
From October 1, 2010 the Finnish Lotteries Act and Criminal Code
tightened the ban on advertising illegal gambling companies
and increased the maximum prison sentence for marketing
unlicensed operators from six months to two years.
Local gambling publications quickly saw advertising revenues
from foreign online gaming firms dry up, and the media has
become increasingly cautious over running unapproved adverts.
Although the regulator has been broadly successful in blocking
advertising from foreign gambling companies, the regulator has
not implemented IP or payment blocking.
RAY moved online at the end of 2010 offering slot and casino
games as well as poker throughout Finland. Since then, internet
gaming for RAY has grown into a lucrative product.
qualification tournaments to participate at Casino Helsinkis ray.

fi tournament.
Still, efforts by Finnish slot association RAY to draw poker players
away from offshore websites have so far had mixed results.
RAYs online casino games have proved far more popular than
its poker network, which cannot compete with the sheer number
of players on foreign websites, since it launched at the end of
2010.
Jouni Laiho, the administrative head of the Finnish lotteries in
the Police Administration, noted that in 2012 around 70 websites
were offering games in Finnish by companies mostly located in
Malta, but he admitted the regulator could do little to prevent it.
Laiho said: According to Finnish law it is illegal but we dont
have any means to stop it because the procedure is legal in
Malta, and there are no effective means to persuade Maltese
authorities to stop gaming opportunities offered from there.
Blocking adverts in Finnish media that we can do. But
we lack means to tackle the operation itself, said Jouni
Laiho, administrative head of Finnish lotteries in the Police
Administration.
The land Islands, a Swedish-speaking autonomous region of
Finland, has licensed lands Penningautomatfrening (Paf),
which is the landic version of RAY and Veikkaus combined,
which also offers games into mainland Finland.
FRANCE
Revenues at Frances 195 casinos have drifted downwards

in the past three years and at 2.3bn now stand some
2.6 percent lower than 2010, compounding a further 18
percent slump experienced since 2007 as restrictions on
player identity checking and the 2008 smoking ban took
hold.
Just 65 of Frances casinos saw any increases in their GGR
between 2011-2012; the remainder suffered a contraction in
revenues.
Tables games win has grown steadily to 221m in 2012, up
more than 5 percent on the year before, but this gain has
been largely offset by softer machine hold, which was
down 2.5 percent in 2012 at 2.054bn.
There were more than 1.6m fewer visits to Frances casinos
in 2012 than in 2011, a 4.7 percent decline, as a widespread
economic malaise weighed on consumer confidence
and competition from online gambling, first legalised in
France in 2010, became entrenched.
Frances casino sector, a significant employer, has shed
jobs in recent years. 15,500 staff work in the nations
casinos compared to 17,500 in 2010.
Frances principal casino operators have

consolidated their businesses in recent
years but have been unable to take
advantage of the controlled opening of the
online gambling market.
In 2012, RAYs online gambling revenues reached 43.5m, up

62 percent in comparison to the previous year. The number
of customers registered with the firms services reached
approximately 244,000 in April 2013, a figure that includes
customers registered with their mobile gaming services.
The RAY gaming service (www.ray.fi ) offers more than 150
different games, including casino table games and online poker.
Between 2011-2012 the group prioritised the cross selling of
Casino Helsinki and www.ray.fi. The www.ray.fi website offers
weekly chances to win seats at Casino Helsinkis tournaments.
Another example is a dedicated ray.fi tournament where all
100 participants were exclusively chosen from several online
42
43

Market Data
Population
Currency
Euro
GNI (Gross National

Income)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
AA1 from A+ (Moodys November 2012)
The French Casino Market

Regulator
Casinos fall under the authority of the Ministry of Finance
and the Ministry of the Interior, which in turn have set up the
Commission Suprieure des Jeux (CSJ) to grant licences and
administer casino regulations.
According to the 2007 decree that regulates casinos (Arrt
du 14 mai 2007 relatif la rglementation des jeux dans les
casinos), licences are granted by the Ministry of Interior on a
temporary basis.
The licence issuance follows a complex procedure involving
the creation of a local government advisory panel. This body
is composed of MPs, mayors and senior civil servants who
examine a certain number of applications for the creation,
renewal or extension of casinos during their monthly sitting.
Each application is considered according to a number of criteria,
varying from the population of a town to local competition, local
economic interests, as well as public morality. The CSJ then issue
a positive or negative opinion for the application, which is passed
to the Ministry of the Interior to make a final decision.
Employee training must take place annually.
Both Partouche and Lucien Barrire chose to shutter their online

poker operations in 2013, finding competition too fierce in the
shrinking market dominated by companies including Winamax,
PokerStars and PartyPoker.
LB Poker, which provides online poker for national lottery
Franaise des Jeux and casino firm Groupe Lucien Barrire,
announced it would shutter the BarrierePoker.fr website on
September 30 2013.
From this point of view the lack of market growth has not
led to a redistribution of the cards in favour of the new
French players like BarrierePoker.fr.
Smoking Ban
A law enacted on January 1, 2008 banned smoking in public
places in France.
In France, according to national legislation, casino entrants must
be at least 18 years old.
Until 2007 casino players paid a fee to gain entrance to a French
casino, set at a minimum amount for one day access of 10.
Taxation
Casinos are taxed 10 to 80 percent of their gross gaming
revenues. Part of this taxation is given to local authorities.
In 2012, French casinos paid 1.229bn in taxes, a decrease of
26m or 2.1 percent on the year before.
Poker
All large casino groups in France have obtained online gambling
licences, to expand their poker products and benefit from cross
marketing with their land-based venues, but the market has
proved tough for the land-based operators.
machines, meaning casinos will now be able to let their

customers play slot machines after the closure of their table
games.
The decree from May 2007 abolished this practice and included
new provisions that require all casino players to register, free
of charge, before being allowed to play. This measure was
implemented originally to restrict access to minors, monitor
financial transactions and enforce self-exclusion programmes.
After years of declining attendance and the closure of numerous

venues, a 2007 decree gave French casinos the right to organise
Texas Holdem poker tournaments, in an attempt to boost visitor
numbers. Although the impact was not immediate, in the past
three years declines in attendance have stabilised, and revenue
declines have eased.
Before the regulation of the market a number of operators

had already established their positions for several years
gaining the reputation and the business experience and
consolidating player databases, LB Poker said.
44
The Ministry of the Interior conducts inspections every three

years and each time a casino renews its new agreement to
operate usually at a maximum of every five years.
At the beginning of 2013 France had 195 casinos, of which

approximately 115 belonged to four large groups: Partouche,
Barriere, JOA and Tranchant.
In the second quarter of 2013 online poker wagers declined 16

percent, to 1.27bn, the biggest drop since regulation began.
French casino revenues have seen substantial overall decline

since 2007 when overall gross gaming revenues stood at
2,788m.
French casinos typically reach their own agreements with local

towns and municipalities where the property is situated and
participate in the funding of treatment centres and helplines to
help players who are vulnerable to gambling addiction.
In particular, the company said it had struggled to compete with

the number of operators that were already well established in
France before the market opened in 2010, and vowed to focus on
its core land-based business.
Frances Licensed Casino Market
Self-Exclusion
Since 2007 the Linterdiction volontaire de jeux, or selfexclusion programme, has introduced a general prohibition on
the access to online games, as well as land-based casino games
and gaming halls; however, the incumbent operators PMU and
FDJ are not subject to this requirement for their land-based
activities, a discrepancy that many observers see as a distortion
of fair competition.
By contrast, the government collected 327m in taxes on online

games the same year, an increase of 6 percent from 2011.
In France, slot players are taxed at 12 percent when their
winnings exceed 1,500, at which point the fiscal law begins to
regard them as professional players.
Originally created for land-based casino gaming the programme

was extended to online games by the Online Gambling Act 2010.
Persons who appear on the list of self-excluded players cannot
enter a casino or gaming hall or open a player account on a
licensed website.
Once on the list, the prohibition lasts for three years. If the
applicant wishes to stay on the list after three years, no specific
action is needed as the ban remains until the person concerned
asks explicitly the Ministry of Interior to be removed from the list.
Some land-based casinos have created their own list entitled
A.N.P.R. A player can ask to appear on this list to be banned
from playing one specific game in this casino. This measure may
not stop the player from entering other casinos.
According to the 2007 decree regulating casinos, operating
hours for each casino are defined in the licence granted to each
casino.
In February 2013, an amendment to this decree authorised
the separation of operating hours for table games and slot

VLTs and slot machines may be played in licensed casinos only.
Slot machines may accept pre-paid cards or be fitted with bill
acceptors in France.
Remote Gambling
Because of the dominant position of the land-based duopoly
of PMU and FDJ, gambling constitutes an important source
45
of revenue for the state. Successive governments tended to

adopt a protective attitude against allowing a greater role to
private operators in the market, but the activities of unlicensed
operators, and the realisation of economic benefits to be gained
from the taxation of online gambling, prompted a gradual
opening of the French market in 2010.
Early enthusiasm for the highly-taxed and regulated market was
short-lived and by April 2013, just 21 online operators remained
in France, down from 35 at the beginning of 2012 as the market
consolidated and operators exited the market.
These elections produced a new socialist government that has so far

given no indication that it will proceed with any revision of the law.
Online gambling in France also has a dedicated regulator, ARJEL
(Autorit de Rgulation des Jeux en Ligne), which has signed
bilateral agreements with the UK Gambling Commission, the
Spanish regulator DGoJ and the Italian regulator AAMS, and
has indicated its interest in cooperating on, among other things,
the pooling of poker liquidity, responsible online gambling,
managing online payment fraud and combating match-fixing.
GERMANY
Although their earnings declined, Germanys casinos

still carried some of the highest gaming tax burdens
in the World in 2012, sending 280m to their respective
treasuries, just 2 percent less than a year before.
Germanys 73 casinos earned revenues of 625m in 2012,
3.8 percent less than a year before and nearly 5 percent
below the 2010 figure of 657m, as consumer spending
remained under pressure throughout Europes largest
economy.
Still online sports-betting revenues grew in 2012, with only nine

operators offering bets on sports. There were 16 sports-betting
operators with a licence in December 2011, of which almost half
had pulled out of the French market in one year.
The number of casino visits continued to shrink and fell

below 6m in 2012 to 5.9m, a fall of more than 8 percent
since 2010.
Online casino games were excluded from the controlled

opening of the online market in 2010 and have continued to be
unavailable to licensed operators.
Table gaming revenues were worst hit, contracting by 7.5

percent between 2011 and 2012, while slots shed just 1.8
percent of their win.
In France, operators which have mostly failed to turn a profit

since the opening of the market in the country were hoping that
the mandatory revision of the law scheduled for late 2011 would
address the issues of heavy compliance costs and a high tax
burden.
Since 2008, the gross gaming revenues of licensed

casinos have dropped 42 percent and the number of
visitors has fallen 33 percent. The casinos have faced
smoking bans, restrictions on their advertising, tougher
ID rules and the effective denial of ATM cash access for
players, combined with competition from unlicensed
online operators and an expanding number of arcades.
However, the former French government decided to maintain

the status quo until the presidential elections were held in May
and June 2012.
46
At the end of 2012 there were a total of

73 casinos in Germany, around half of
which are state-owned and the other half
mainly owned by private state-licensed
enterprises.
47

Market Data
Population
Currency
Euro
GNI (Gross National

Income)
$44,270 in 2011 (World Bank Data)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
Standard & Poors credit rating for Germany

is AAA
The German Casino Market

Regulator
By law games of chance are regulated by individual state laws
and the common State Treaty in conjunction with corresponding
casino implementation laws. The Ministry of the Interior is the
regulatory and supervisory body in most states, but in some
states the responsibility lies within the Ministry of Finance.
However, less regulated slot machines in more than 60,000
locations in arcades and bars are regulated by commercial law
on a federal level.
According to the casino laws, the land-based casinos have to
abide by a demanding licensing system whereby the licences are
strictly limited in numbers and locations in addition to further
restrictions on operations.
Land-based casinos have to follow very elaborate regulations
with regard to consumer protection and rules to prevent money
laundering and must comply with restrictions on advertising.
They are subject to permanent on-site control and supervision by
the authorities.
There is also a special taxation regime for licensed casinos. The
level of taxation amounts to up to 90 percent of gross gaming
revenue (GGR).
On July 1, 2012 amendments to the Interstate Treaty on
Gambling, the core gambling legislation in Germany, entered
into force introducing important changes, but the amendments
remain bitterly contested among industry stakeholders, with
casinos, online bookmakers, arcades and lotteries disagreeing
on the tax and regulatory burdens.
When the amendments were submitted to the European
Commission, the commission responded with concerns regarding
compliance with EU law in terms of consistency and coherency.
Online casino games are still not allowed at all. However, in
a last minute move the state of Schleswig-Holstein assigned
23 online licences for virtual casino games at the end of 2012
and the beginning of 2013. This development added confusion
to an already messy legal situation for gaming operators and
has hindered enforcement against activities that are otherwise
clearly illegal in Germany.
48
Smoking Ban
Germanys casinos contribute substantially to good causes on a

voluntary basis, while most state gaming laws attribute a share
of gaming tax to good causes or sports.
Smoking regulation is the regulatory remit of the states.
Although the regulation varies state by state, generally smoking

is banned in casinos, with some states allowing for exceptions
such as separate rooms for smokers.
Germanys land-based casinos today abide by a wide range of

legal requirements with regard to player protection measures,
ranging from strict registration and identification procedures
to the establishment of player protection concepts. Casino
employees participate in regular training and the casinos
themselves comply with responsible advertising controls and
comprehensive anti-money laundering measures.
Arcades
All player protection measures contained in the interstate treaty,

specifically the social concept requirement and the joint-client
exclusion system were originally initiated and established by the
German casinos on a voluntary basis.
Since 2011/2012 states, for the first time, via the Interstate
Treaty, have introduced location-based regulation with several
restrictions, such as minimum distance requirements, advertising
restrictions and opening time cuts.
In 2013 the parliament and the federal council, the Bundesrat,
demanded further amendments to curb the federal Gaming
Ordinance, the Spielverordnung, to strengthen player protection
rules under the act.
Germanys Licensed Casino Market
The Interstate Treaty requires licence applicants to submit a

so-called social concept in which they outline how they will
guarantee a high level of player protection, in particular by
means of early diagnosis and prevention. They are also required
to provide information and warnings on the addiction risks of
gambling and on the probabilities of possible wins and losses.
Casinos are regulated on a state level and the 16 German states

are entitled to license, regulate and tax casinos independently.
Together land-based casinos also operate a joint client exclusion

system that applies across their industry.
The states set a limit on the number of casinos in their territory, and
these quotas vary from region to region. Each state passes its own
legislation regarding the types of games it permits in the casinos
within its borders. Some states such as Hesse, Brandenburg and
Bavaria have stipulations as to where casinos can be located. Eight
states allow private operators in their gaming laws.
Casino licence holders are required to develop and document

individual programmes for player protection, which incorporate
records of staff training, and interviews with vulnerable players.
Licensed casinos are under enormous economic

pressure due to inconsistent regulation and a lack of
prosecution having brought about an uneven playing field,
and shifting more than 50 percent of casino revenues into
grey markets with little or no consumer protection. Otto
Wulferding, chairman Deutscher Spielbankenverband e.V.
There are a total of 73 casinos in Germany, around half of which

are state-owned and the other half mainly owned by private
entities. They are run by 20 different state-licensed private and
public companies and state-operated enterprises.
Licensed casinos can be found in the following states: BadenWrttemberg, Bavaria, Berlin, Brandenburg, Bremen, Hamburg,
Hesse, Lower Saxony, Mecklenburg Western Pomerania, North
Rhine Westphalia, Saarland, Rhineland-Palatinate, Saxony,
Schleswig-Holstein and Thuringia. Unregulated and less strictly
regulated competition from online casinos and slots located in
arcades and bars has contributed to the economic pressures that
have forced several casinos out of business.
Barring can take place either on the request of the player, at the
initiative of casino operators, or by third parties that are directly
involved. The barring lasts at least one year. After this period the player
can make a written request to lift the ban. Operators can be held liable
for losses if they fail to prevent vulnerable players from playing.
All licensed casinos are obliged to control access to slots and
table gaming areas to ensure that self-excluded gamblers are
not permitted to play.
The participation of minors in gambling is forbidden. Although
generally players should be at least 18 years of age, some state
casino laws require players to be at least 21 years of age.
After a rapid proliferation of slot arcade locations, and the lifting

of technical restrictions that brought street machines closer
in format to casino slots, the states have pushed back against
federal ordinances to regain control of street gaming and its
associated hazards.
The amendments include lowering hourly maximum winnings

and losses, banning slot machines from betting shops,
restricting the operation of slot machines in restaurants and
bars, banning simultaneous play on more than one slot machine,
as well as introducing obligatory breaks during playing time.
The federal government has so far not taken the opportunity to
follow the states requests for amendments, leaving an uneven
playing field for the operations of games of chance.
The European Parliament has called member states with
remarkable clarity to tackle illegal gambling. Whoever
appeals to the principle of subsidiarity must take action
himself. Martin Reeckmann, chairman, Bundesverband
privater Spielbanken in Deutschland e.V. (BupriS).
Remote Gambling
Offering online casino gambling is generally strictly forbidden in
Germany. Land-based casinos have to comply with the complete
ban on online casino gaming and poker, and their use of this
distribution channel is completely restricted.
Germanys blanket ban on online gambling was lifted to a
certain extent with amendments to the Interstate Treaty on
Gambling that entered into force on July 1, 2012.
However, the provisions will only allow sports betting, horse
race betting and lotteries to be offered online, while the legal
situation for land-based casinos remains unchanged.
In 2012 the state of Schleswig-Holstein issued 23 licences to
mostly non-German operators of online casino games, and 25
licences for sports betting, with the proviso that the licences did
not apply beyond its state borders.
German land-based casinos did not receive any licences in the
process. The licensing regime survives, even though a new
coalition has repealed the legislation in Schleswig-Holstein and
joined the other 15 states.
49

Nationwide, a chronic lack of enforcement measures against
unlicensed online gambling have created a situation whereby
Germany is the second largest black market for online gambling
in Europe according to the European Commission.
For online poker the situation is even more pronounced and
600,000 online poker players help make Germany the biggest
black market in Europe.
The regulator of Hesse is currently coordinating the licensing
process for the 20 sports-betting licences that can be assigned
under the latest revision of the Interstate Treaty.
Those licences will be valid in all German states, and licensing
fees will likely be based on the operators expected annual
turnover.
Casino tax in each of the 16 states is as follows:

BadenWrttemberg
GGR up to 20m - 50 percent

GGR which exceed 50m - 60 percent
Bavaria

GGR over 25m - 35 percent
Berlin

GGR exceeding 10m - 35 percent
Brandenburg
GGR up to 3m - 25 percent.
GGR between 3m and 4m - 30 percent.
GGR between 4m and 5m - 35 percent.
GGR between 5m and 7.5m - 45 percent.
GGR exceeding 7.5m - 60 percent.
Bremen
50 percent of GGR, with an additional fee of 30 percent

of GGR.
The senator for interior and sports affairs, with the
permission of the senator of financial affairs, can reduce
the casino tax to 25 percent of GGR.
Taxation
Taxes on German casino profits are among the highest in
Europe, but player winnings in Germany are not subject to
income tax except for the earnings of professional poker players.
Hamburg
90 percent of GGR.
This is made up of a gross revenue tax of 70 percent plus
a special additional gross revenue tax of 20 percent. The
special additional gross revenue tax can be lowered,
provided no fair profits remain at the operator.
Hesse

GGR between 25m and 50m - 55 percent
In addition, the licensee is required to pay a levy of:
GGR exceeding 50m - 20 percent
Lower Saxony
50 percent of GGR; plus if the GGR exceed 1m.

GGR over 10m - 25 percent8
MecklenburgWestern
Pomerania
40 to 80 percent depending on GGR, subject to an

additional levy.
North RhineWestphalia
50 percent of GGR.
There is a tax allowance amounting to 1m. In the first
three years after opening a casino, this tax rate can be
lowered to 35 percent.
Saarland

The tax rate can be lowered to 30 percent until up to five
years after the opening of the casino.
RhinelandPalatinate

GREECE
Greeces nine casinos have seen their income slump in

the economic crisis that has stricken the country, as nongaming spend has fallen away and their largely domestic
customers have gambled less on each visit.
A formidable illegal machine and casino market exists
in Greece, forcing licensed casinos to raise their levels
of marketing spend as they struggle against the black
market operations.
The Greek casino sector has struggled in the worsening
economic climate as the government imposed austerity
measures in return for its total of 240bn in international
bailout money since 2010.
Although the Greek betting monopoly OPAP claims a
monopoly on online gambling, its bid for exclusivity
has sparked one of the fiercest disputes over restrictive
gambling legislation in Europe. Excluded private
operators continue to contest their monopoly in the Greek
and European courts.
OPAP purchased from the Greek government the right to
operate 16,500 VLTs in Greece and the right to sub-license
another 18,500. The company expects VLTs to make up
half of the gross gaming revenues in time, a situation
that would likely have a negative impact on land-based
casinos, but delays in framing regulations have meant no
VLTs have yet been installed.
A European Commission state aid investigation determined
in 2011 that three of Greeces casinos had benefitted from
unlawful state aid in the form of levies on admissions
to casinos that were premised on an equal tax rate
imposed on a differentiated and pre-defined ticket price.
Casino Xanthi
Regency Casino Thessaloniki
Casino Porto Carras
Corfu Casino
Casino Rio
Regency Casino Mont Parnes

Club Hotel Casino Loutraki
Aegean Casino
Casino Rhodes
Greeces Licensed Casino Operators

Club Hotel Casino Loutraki
Regency Casino Thessaloniki
Regency Casino Mont Parnes
Casino Rio
Casino Rhodes
Casino Porto Carras
Casino Xanthi
Aegean Casino
Corfu Casino
Additional levy:
GGR over 50m - 20 percent
50
Saxony-Anhalt
GGR up to 7.5m - 25 percent

GGR between 7.5m and 10m - 35 percent
GGR between 10m and 12.5m - 45 percent
GGR which exceed 12.5m - 50 percent
Casino operators are also liable to an additional levy.
Saxony
50-70 percent depending on GGR.
SchleswigHolstein
GGR up to 10m - 30 percent, with a 10 percent additional

levy.
GGR which exceed 10m - 40 percent, with a 15 percent
additional levy.
Thuringia
GGR up to 2.5m - 25 percent.

GGR between 2.5m and 3.5m - 30 percent.
GGR between 3.5m and 5m - 40 percent.
GGR between 5m and 7.5m - 50 percent.
GGR over 7.5m - 60 percent.
51

Market Data
Population
Greeces Licensed Casino Market
Currency
Euro
GNI (Gross National

Income)

People
Since 1994, when the casinos in Rhodes, Corfu and Parnitha

were the only ones operating legally in the country, several
international companies have come to own or operate casinos
in Greece. There are now nine licensed casinos operating in
Greece.
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
B- from SD (Selective Default) stable outlook

December 2012, Standard & Poors
The Greek Casino Market

Economic Situation
The Greek populations gambling expenditure has historically
been considered among the highest in the world and the
regulated Greek gambling market, including lottery products,
delivers net annual revenues of nearly 6bn for a population of
just 11m.
In the 1990s Greece boasted three out of four of Europes largest
casino properties, with extraordinary levels of turnover.
The countrys northern casino properties including Thessaloniki

have also suffered in recent years from competition from casinos
in the nearby Macedonian gaming hubs of Doiran and Gevgelija.
The day of maximising non-gaming revenues has been
put off indefinitely. Ian Gosling, CEO, Regency Casinos.
Greece has been forced to privatise several gambling assets,

including, among others, its 34 percent ownership in OPAP, 49
percent of Casino Mont Parnes and the total ownership of the
Hellenic Horse Betting Association (ODIE).
The 2008 global economic crisis, which had a harsh impact

on the debt-laden Greek economy, combined with a national
smoking ban introduced in 2009, has decimated Greeces
land-based casinos industry. The continuing perilous economic
circumstances across the country have resulted in unrelenting
declines in revenues, as personal disposable incomes have
contracted.
Regency Entertainment, a subsidiary of BC Partners, operates

two of the largest casinos in Greece the Regency Casino
Thessaloniki and the Regency Casino Mont Parnes as well as
the Hyatt Hotel in Thessaloniki.
Club Hotel Casino Loutraki, which opened in 1995 and is one of
Europes largest casinos, is owned by a consortium of Israeli
backers, Casinos Austria and the Loutraki municipality.
Beginning in 2010, the European Commission investigated three
formerly publicly owned Greek casinos Regency Casino Mont
Parnes, Regency Thessaloniki and Corfu Casino in a state aid
case. The commission analysed the difference in the entry proice
of tickets at these three state-owned casinos and other privatelyowned casinos established in Greece.
After a ten-month investigation the European Commission ruled
on May 24, 2011 that the lower entry fees constituted unlawful
discrimination because it created a fiscal discrimination in favour
of public casinos.
All admission tickets in Greek casinos are taxed at 80 percent
plus VAT on the remaining 20 percent, thus the commission
noted this equates to a 12.48 admission tax per person for
private casinos, while public casinos pay only 4.99.
Siding with Club Hotel Loutraki, which filed the original
complaint, the commission agreed that the lower fees could not
be justified as a way of discouraging persons with low incomes
from gambling. The commission further decided that these three
casinos should repay the difference of entrance fees since 1999.
The Greek government has participation in two casinos, Parnes
and Corfu, but in 2011 announced that it will sell its stake in
Casino Mont Parnes, in which it holds a 49 percent stake, to help
plug the huge fiscal deficit that is currently burdening the Greek
economy. Regency Entertainment holds the operation rights of
the venue until the end of this year.
The Hellenic Republic Asset Development Fund (TAIPED) has
confirmed the sale of the Greek-owned stake in the venue,
appointing Alpha Bank and the Investment Bank of Greece as
financial advisors.
Regulator
The Greek casino sector has also had to contend with

government imposed austerity measures across the broader
economy that have been taken in return for a total of 240bn in
international bailout money since 2010.
Greeces casino customers are overwhelmingly derived from
Greece itself with little significant tourist spend in the properties.
52
Club Hotel Casino Loutrakis contribution, for the period 1995

to 201, to the Hellenic State (including contribution to social
security funds) and local authorities (Loutraki Municipality)
amounted to 1.866m (or 63 percent). Staff costs and benefits
amounted to 442.6m (or 15 percent), investments stood at
145.4m (or 5 percent), share of profits to private investors
settled at 427.3m (or 14 percent), whereas 67.4m (or 2
percent) was distributed to local suppliers and 13.5m (or
0.5 percent) was allocated to corporate social responsibility
activities.
The Hellenic Gaming Commission, the regulator for gaming

activities within the Hellenic Republic, was brought into
existence by ministerial decree on December 20, 2011 and
assumed its responsibilities for Casino Supervision and Control
in October 2013.
While the sale of the governments 34 percent stake in Greek

betting monopoly OPAP was completed in August 2013, and
the sale of the horse betting concession formerly run by
ODIE is imminent, the disposal of the state-owned portion
of Casino Mont Parnes currently has no clear time schedule
and overhanging concerns regarding possibly illegal state aid
200m continue to delay the privatisation process.
The Hellenic Gaming Commission consists of eight members,

with Evgenios Giannakopoulos confirmed as president of the
committee serving a five-year term.
Contributions to Society

National legislation requires customers to be registered and
above the age of 21 to enter the casino premises. Additionally,
Club Hotel Casino Loutraki applies a wide-ranging corporate
social responsibility programme as a strategic choice as part of
its business operation and growth.

Casinos, in collaboration with the Hellenic Centre for

Intercultural Psychiatry and Care, offer a free 24-hour SOS
Hotline for psychological support for those in need, as
well as specially designed therapy programmes. Contact
information for the centre is printed on the back of each
obligatory casino admission ticket.
Casinos, in collaboration with the Hellenic Centre for
Intercultural Psychiatry and Care, train their personnel to
detect gambling addicts that are in need of professional
help and support.
A further key measure is the distribution of newsletters
to casino clients, as well as funding of scientific events
and lectures to increase public awareness, in an effort to
prevent problem gambling. Leaflets concerning gambling
problems and describing responsible gaming are widely
distributed.
Casinos do not serve alcoholic beverages to visibly
intoxicated individuals.
Self-exclusion measures are available for individuals
and immediate family members to exclude other family
members for entry to the casino. The barring is applicable
for at least six months.
Greeces casinos return money to society in a number of ways.

On an annual basis, each casino has to pay a fixed annual
contribution to the Greek National Tourism Organisation,
ranging from 147k to 3.5m.
53
Taxation
Greeces casinos make a one-off payment for the exclusive right
to operate in one of the 12 pre-approved locations. This amount
varies from 4.4m in Corfu to 16.1m in Mont Parnes.
As of November 2012 the gaming tax applied on gross gaming
revenues of the Greek casinos ranges from 22 percent to 35
percent depending on their location and size. Specifically, this
rate is currently set at 35 percent for Korinthos, 32 percent for
Attica, Thessaloniki, Crete, Rhodes and Achaea, 23 percent
for Cyclades and 22 percent for Xanthi. For the casino at Mont
Parnes, the tax is 32 percent if revenues are under 200m,
33.5 percent if revenues are between 200m and 250m, 34.5
percent if revenues are between 250m and 300m and 34.5
percent if revenues exceed 300m.
HUNGARY
On October 10, 2012 all slot machines outside casinos,

totalling some 6,591 units, were banned across Hungary,
granting the countrys three casino properties an effective
slot monopoly.
based casinos, but under the terms of the latest government

regulations VLT players will pay a 10 percent winnings tax and
will be obliged to register for a players card which records their
gambling transactions.
There is currently no winnings tax in Greeces casinos, leaving
casinos to hope that VLTs may act as a conduit for a new
generation of value-seeking players.
The effect of this measure has been to strongly boost the

business of the land-based casinos, making them Europes
best performing casinos in 2012. Visitor numbers leapt by
44.4 percent to 296,000 visits.
Despite the privileged position of the company, OPAPs revenues

have also seen a sharp decline since 2008 when the company
reported revenues of 5.5bn, falling to 3.9bn in 2012, a 29
percent decrease in the companys revenues.
Overall gross gaming revenues jumped more than 31

percent in 2012, but slot revenues, when measured
separately, more than doubled, rising by 166 percent.
Remote Gambling
Gaming taxes paid by Hungarys casinos also rose sharply

by 27.9 percent from 6m to 8m.
The situation with regard to online gambling remains confused

in Greece. OPAP claims a monopoly on online gambling games
but a public tender for online licences, enabled by the 2011
gambling law, has yet to occur.
In 2011 Greece issued temporary licences to 24 operators,
conditional on the retrospective payment of two years (FY2010
& FY2011) of taxes based on their history of their operations in
Greece. Subsequently, the Hellenic Gaming Commission issued
warning orders on November 5, 2012 to all unlicensed operators
currently serving the Greek market, ordering them to stop
providing services in Greece or risk fines ranging from 200,000
to 500,000 and criminal sanctions
A formidable illegal machine and casino market exists

in Hungary and, as a result of the slot machine ban, the
state has suffered significant losses in taxation revenues
that it formerly levied on the slots industry.
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In June 2013 the Hungarian National Assembly approved

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In July 2013 the National Security Committee of the

Hungarian parliament supported a proposal to introduce
up to ten new Class II casino licences in an invitation-only
tender process.
A further tax of 80 percent plus VAT on the remaining 20 percent

is levied by the state. In 2012, this amounted to more than 20m.
Additionally, 2 percent of gross gaming revenues is allocated
to the municipality authorities on a monthly basis, with the
exception of one casino that pays 4 percent.
On an annual basis, each casino has to pay a fixed annual
contribution to the Greek National Tourism Organisation,
ranging from 147k to 3.5m.
VLTs
In October 2011 OPAP paid 560m to the Greek government for
the exclusive right to operate and sub-lease 35,000 video lottery
terminals (VLTs); a right which was confirmed in the contentious
Gaming Law 4002/2011.
The machines, which are to be installed in 25-50 machine
halls throughout Greece, threaten the revenues of land-
54
55

Market Data
Population
9. 94m in 2012 (World Bank Data)
Currency
Hungarian forint (HUF)
GNI (Gross National

Income)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
BB+ with a stable outlook, Fitch Ratings,

December 2012
The Hungarian Casino Market

Regulator
As of January 1, 2007, regulatory oversight of the gaming
industry has been the responsibility of the Gambling Supervision
Department of the Central Bureau of the Tax and Financial
Control Administration, since 2011 called the National Tax and
Customs Administration (NAV)).
Hungarys Licensed Casino Market
The Hungarian gaming market currently consists of the state
operator, Szerencsejtk Zrt (SzRt), which holds a monopoly
over the lottery, and betting operations, with the exception of
horse race betting and bookmaking, as well as casinos, poker
clubs and horseracing. SzRt also holds the exclusive right to
distribute number lottery games and instant tickets throughout
Hungary.
The Ministry of Finance has revoked the priority investment

status of two other projects, Kings City and Dream Island,
amid controversy and legal wrangling, and in September 2013
repurchased the land needed by the Dream Island property.
In July 2013 the National Security Committee of the Hungarian
Parliament supported a proposal to introduce up to ten new
Class II casino licences through an invitation-only tender
process, accepting arguments that national security would be
best served through this strategy, although details of the plans
remain limited.
all gambling concessions, nearly double the previous level.

This estimate includes both online and land-based taxes, and
explicitly notes that the government expects to derive revenues
from nine new Class II casino licences to be granted in 2014.
Taxation
Poker
On April 21, 2013 casino tax law amendments came into force,
which means gross gaming casino revenues exceeding HUF10bn
will only be taxed at a rate of 10 percent.
In Hungary, poker historically has been unregulated and

untaxed; however, an amendment passed on May 1, 2010
specified that card games including poker fall under the
definition of gambling operations and activities for conducting
contests of chance and may be organised in card rooms. Texas
Holdem poker is available only at Casino Tropicana. A 40
percent gambling tax, calculated on gross gaming revenues,
applies to the card rooms.
Since the new law has entered into force authorities have made
several spot checks throughout the country and two major poker
halls decided to close down following raids.
In addition, three mega casino projects have been proposed in

recent years, but little progress has been made.
In 2008 the Seminole Hard Rock brand put forward a plan for
a property named Vegas in Europe located in north-western
Hungary, close to the Austrian and Slovak borders, with the early
stages scheduled to be completed in 2012. This timescale has
not been met, but in 2013 two new investors were added to the
project.
The Eurovegas Hungary Group was granted a gaming
concession licence from the Hungarian government in 2006,
which allows for up to five Category 1 casinos (super casinos)
to be constructed with an unlimited number of slots and tables.
These licences are valid for 20 years, with a possible ten-year
extension.
56
Concession fees for a casino in Hungary differ depending on the

location of the casino. For casinos located in Budapest and Pest
County, annual fees of HUF631.2m were levied for Class I casinos
and HUF368.2m for Class II casinos in 2013. For casinos located
elsewhere, the annual fees levied in 2013 were HUF526m for
Class I casinos and HUF52.6m for Class II casinos.
When calculating monthly turnover for the purposes of taxation,
casino operators include 50 percent of any tips received in
monthly gambling receipts.
In 2012 the Hungarian Poker Association reported that there

were approximately 100 illegal poker tables throughout
the country, 50 of which can be found in Budapest. Around
HUF0.5bn per year in tax revenues are being lost due to the
unlicensed tables, according to estimates.
VLTs
There are three licensed casinos in Hungary: Casino Tropicana,

is owned by Szerencsejtk Zrt, Casino Sopron is owned by
Casinos Austria as a majority shareholder and Casino Las Vegas
is operated as a private business enterprise.
Prior to 2012 the Hungarian casino market had entered a
downward spiral, which was reflected in the dwindling revenues,
as well as employee numbers. In 2010 casinos generated
revenues totalling 22m, down by 6m compared with the
28m achieved in the previous year.
Casino gaming tax, including tax on slot machines operated in a

casino, is 30 percent of the gross gaming revenues.

National legislation requires customers to be 18 years of age and
registration is required on a first visit.
Economic Situation
The consequences of the eurozone economic crisis continue to
be felt in Hungary, with the government seeking a sequence of
spending cuts and tax increases.
Players can self-exclude upon their own request or upon the

request of a legal guardian for up to five years. Once the casino
has recorded the ban it remains in place and cannot be revoked.
Smoking Ban
The centre-right Fidesz government is struggling to maintain the

deficit below 3 percent; the level needed to allow the country to
continue to access EU funding, introducing new taxes on public
utilities and extending a 2010 crisis tax on banks.
On January 1, 2012 a ban on smoking inside public places entered

into force. Casinos had hoped for an exemption from the ban but
their exceptional status was overruled on the day of the bans
entry into force.
In its 2013 budget, which the Hungarian parliament approved on

December 11, 2012, gambling concession fees were set to deliver
HUF1.1bn to the budget in 2013.
Problem Gambling Prevalence
According to the latest draft 2014 central budget, the Hungarian

government expects to collect HUF2.1bn in total taxes from
A prevalence study published by Ipsos Zrt. in 2010 indicated that

around 1.2 percent of the Hungarian population over the age of
18 is heavily addicted to gambling. With Hungarys population of
about 9.9m, this translates to around 100,000 people.
Estimates from EUROMAT, the European slot industry

federation, indicated that there were more than 24,000 gaming
machines in Hungary in 2010. However, tax increases of more
than 500 percent, levied in 2011, resulted in a contraction of the
slots industry to 6,600 machines by the time the outright ban
was introduced in 2012.
State secretary Janos Lazar said the fast tracked ban was needed
because of new information that elements within the industry
posed a serious national security threat and because of a
perceived negative social impact of the machines in the poorest
regions of the country.
Lazar conceded that the treasury expects to lose around
HUF30bn (104m) in tax revenue annually due to the crackdown
but that the shortfall would be replaced by regulating online
gambling.
Magyar Szerencsejtk Szvetsg, the Hungarian Gambling
Association, said the government-led crackdown is a serious
mistake and called on MPs to reject the legislation. Meanwhile,
the slot machine ban, which came into force on October 10, 2012,
is currently being contested by EUROMAT, which requested that
the European Commission examine whether the notification of
the slot machine ban was conducted lawfully.
57
The commission, in its response to EUROMAT, noted that it was

in discussion with Hungarian authorities on the issue.
Its a great step for Hungary to implement the new
online gambling rules. It opens up the gate to gambling
organisers to launch their licensed sites in Hungary, said
Gbor Helembai, partner at the Budapest-based law firm
Forg, Damjanovic & Partners.
Remote Gambling
An online gambling bill passed in July 2013, bringing under
regulation a sector that had grown rapidly in Hungary both in
betting and poker.
The draft law, which was sent to the European Commission in
January 2013, was delayed until June after it received a detailed
opinion from Malta.
The bill envisions an unlimited number of licensed operators
for online casino, card games and sports betting, authorised
by the National Tax and Customs Administration (NAV) with a
maximum licence length of five years at a time.
One of the only existing licensees, state lottery Szerencsejtk

Zrt (SzRt), launched its new online sports betting website
Tippmixpro in June 2013, in partnership with Gtech.
Each concession costs HUF 100m (350,000) per year, with a 20
percent gaming tax and 2.5 percent regulatory cost; costs which
are viewed as high by many industry observers.
ITALY
In Italy, overall spending on betting and gambling rose 9

percent to 87bn in 2012 from a year earlier, but the landbased casino sector saw its own total revenues shrink by
18 percent to 364m, from 449m in the year before.
A far-reaching expansion in betting and gambling
offerings in the Italian market since 2006, and ongoing
economic turmoil in the wider national economy, have
led to several years of double digit declines in revenues
for Italys four casinos, but recent results have begun to
suggest an easing of the sectors contraction.
Sanremo
Poker tournaments sponsored and hosted by operators in

Italys competitive online cash poker market have proved
a bright spot in an otherwise dismal picture, boosting
visitation in several land-based properties.
In 2013 Campione DItalia saw 2,600 players take part
in a poker tournament, the best performance ever for a
European casino.
A formidable illegal machine and unlicensed online
casino market exists in Italy, where new games are
frequently made available ahead of official approval in
Italy.
The recession-hit country now has some 380,000 slot
machines and 50,000 regulated video lottery machines
in operation in arcades across the country, but is also
experiencing a widespread political and media backlash
against the machine industry.
58
Campione
St Vincent
Venezia
Casin di Venezia, Casin Sanremo, Casin

de la Valle - Saint Vincent, and Casin
Campione dItalia
Italys four bricks-and-mortar casinos
(Venezia, Sanremo, Saint Vincent and
Campione DItalia), all in the north of
the country, enjoy a special regulatory
status. In 2013 Campione DItalia became
the leading single-location casino in Italy
in terms of turnover, overtaking VeniceAirport.
59
Market Data
Population
Currency
Euro
GNI (Gross National

Income)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
BBB from BBB+ with a negative outlook,

Standard & Poors, July 2013.
The Italian Casino Market

Economic Situation
Overall, Italys land-based industry suffered a contraction of 18
percent in 2012, with Casino di Venezia claiming the title of best
performer in the sector with turnover falling 16.3 percent.
Casin di Venezia, the largest of the four concessions which

is currently subject to a politically contentious sale process,
saw overall spend in the first half of 2013 fall by 7.6 percent to
55.67m as slots spend declined 12 percent. Table games spend
fell 7 percent, despite a fractional increase in visitor numbers of
0.26 percent to 402,000.
Recent Key Regulatory Developments

Online casino gambling became legally regulated in 2011,

presenting new challenges to the land-based sector.
Previously, between 2007 and 2011, only online poker was
legal.
Although legislated for in 2011, online slots first became
available in December 2012.
In September 2012, the Decreto Balduzzi, a broad health
and welfare bill, established additional measures with
regard to the advertising of gambling services in Italy.
The law mandated the provision of correct information
about actual odds of winning on each game type, required
additional information about risks of gambling addiction,
and outlawed the involvement of minors.
The Decreto Balduzzi came into force on January 1, 2013.
In 2013 the casino group Federgioco adopted a selfregulation code for advertising and communications that
adopted the existing legal obligations but also sought to
create a culture of virtuous behaviour going beyond the
minimum legal requirements, for its gaming operators.
Smoking in enclosed public places has been prohibited in
Italy since 2005.
should know that the people striking are earning more than
80,000 a year.
Underscoring the industrial action is a broader uncertainty over
the future of a part of the land-based gaming industry which
is continuing to suffer revenue declines while new products,
including low margin VLTs, gain in popularity.
From 2005 onwards, visitors to casinos have had to pay a fee
even to play high payout slot machines, but competition from
VLTs that are available on every high street with maximum
payouts of 500,000 have increasingly made that revenue
model obsolete.
Sanremos casino last year announced a new plan of action that
would see investment over three years of 7.5m in the gaming
establishment, including a new initiative to make entrance to the
casino free from March 4, but employees responded by staging
a walkout on the first day of March.
Italys Licensed Casino Market
In 2012 total revenues for the industry amounted to 364m, well

down on 2011s 449m, and a further decline is likely in 2013 as
the industry faces up to the effect of competition from online
slots that were introduced in December 2012. Of the total spend
in land-based properties in 2012, slots accounted for the largest
share at 203.8m, whereas roulette accounted for just 60m.
Visitor numbers also tumbled in 2012 as 2.6m players sat down
in Italys casinos, well down on the 3m figure for 2011.
The continuing contraction of revenue in the casino market
has resulted in local governments, which control the casino
venues, to push forward plans for the privatisation of their local
casinos, as the losses of the venues have to be assumed by the
authorities in most cases.
In recent months, helped by a significant revival in table game play,
Italys four land-based casinos have broken their run of double-digit
turnover falls but machine spend has continued to drift.
The most recent Federgioco statistics suggest that total spend
in Italys casinos declined 7.4 percent in the first half of 2013,
with slot spend falling 9.5 percent year-on-year, but table games
slowed their precipitous fall as players staked just 4.4 percent
less.
Casino drop of 155.8m in the first six months of the year
comprised 92m from gaming machines and 62.5m from table
games.
Casino Campione proved to be the the most resilient Italian
casino, defying the effects of the economic crisis with the lowest
drop in revenues recorded between 2010 and 2011.
Casin Sanremo sustained a 10 percent year-on-year fall in spend
during the first half of the year with turnover down to 22.5m, but
June witnessed a 15.5 percent year-on-year jump in turnover.
60
Poker
The only bright spots in an otherwise gloomy picture have come
from spend on Holdem poker, which was up 128 percent as a
result largely of tie-ins with online firms.
Regulation
Italys regulatory framework for the supervision of gambling
operations is one of the most centralised legal regimes in the
world, but casino operations in the country remain controlled by
local authorities in the areas where the venues are located.
In Italy there are four land-based casinos, totally under public
control, and regulated by the Ministry of Internal Affairs.
Gambling operations in Italy outside casinos, including slot
machines and online, are controlled and regulated by the
Agenzia delle Dogane dei Monopoli (ADM) (previously known
as Amministrazione Autonoma dei Monopoli di Stato (AAMS). In
Italy all four casinos have also been authorised to offer remote
gambling services under the control and supervision of the ADM.
The change in the name of the Italian gambling authority was
introduced in 2012 as part of the re-structuring process of the
Italian administration. The Amministrazione Autonoma dei
Monopoli di Stato was merged with the Agenzia delle Dogane
(Customs Agency).
Increasingly widespread and popular calls for a reduction in the

number of slots in bars and amusement arcades in Italys four
casinos are giving the casinos some reason to hope the worst
of their declines may finally be over. Additionally, proposals
first mooted in 2011 that 1,000 small-stakes poker rooms might
be introduced across the country as part of the Manovra fiscal
stabilisation measures have now faded.
However, a multitude of other factors have weighed on Italys
casino sector.
Strikes
Casinos in both Venice and Sanremo suffered industrial action
during 2012 and 2013, despite hopes in November that unions
representing casino workers had headed off unrest through a
tentative agreement with employers.
The stakes are high on both sides. According to Giorgio Orsoni,
Mayor of Venice, the reason for two strikes in January was
because the workers earn too much. Casino di Venezias
managing director Vittorio Rav told local press that the city
Poker tournaments sponsored by online operators have proved

a lifeline for Italys four land-based casinos.
All four operators have, to some extent, partnered with online
poker firms to serve as venues for poker tournaments.
The most resilient casinos, however, were the ones with the
most developed poker strategies.Italys second largest casino,
Campione dItalia, close to the affluent Milan market, saw
sales fall 16.5 percent, but visitor numbers fell only 3 percent to
664,000.
Carlo Pagan, managing director of the company, declared: In a
situation of general decline for the traditional casino sector, the
performance of Casin Campione dItalia should be considered
positive in terms of facing up to the crisis, and the company has
broken all records with regard to share of both turnover and
attendances.
The casino has been at the forefront of developing agreements
with the online poker world and is currently hosting the Italian
Poker Tour organised by Titan Bet, as well as actively targeting
61
Chinese and Russian visitors. Its market share increased from

25.7 percent to 27.2 percent.
In common with the large number of venues in operation across

Italy, local authorities establish the times of operation of casinos.
Sanremo also published data showing that turnover so far this

year has reached 15m, due in large part to the staging of weekly
poker tournaments, and in particular the Italian Poker Tour event
which attracted more than 1,000 entrants who went on to play
on other casino products in the venue.
Taxation
The management is also preparing to offer cash games to

accompany the regular poker tournaments.
Competitive Offers
In addition to nearly 50,000 VLTs that are available on every high
street and which offer maximum payouts of 500,000, Italys
casinos are also coming to terms with competition from online
machines too.
The success of online slots in Italy, which according to recent
figures from ADMS technical partner SOGEI have grown
quickly to turnover more than 1.3bn since their introduction in
December, continues to give rise to concerns that online casino
offerings are beginning to cannabalise those of land-based
properties.
Unsustainable losses:
Casin de la Valle in Saint Vincent recorded a loss of
19m in 2012, a deficit which Luca Frigerio, managing
director of the casino, attributed to three factors: The
closure of half of the hotel as a result of renovation work;
the limit of 1,000 cash imposed by the government has
led many players to go abroad; and the economic crisis
that has affected the sector.
Every casino acts independently in funding organisations
supporting those with gambling addictions, and by participating
in or organising charity events.
In Italy, in absence of any legal obligation, the four land-based
casinos have started enforcing their own player protection
measures, and each casino has an internal commission
responsible for all matters related to player protection.
Typically these player protection measures provide for:
Access only for people above 18 and control of identity/age
at registration; self-exclusion options and measures are made
available.
Informational material about gambling addiction and the help
available to combat gambling addiction.
Staff at the casinos are trained (through meetings and training
material about gambling addiction) to recognise characteristic
problem gambling behaviour among their players.
62
In Italy there is no specific gaming tax that applies to casinos.

Every casino pays ISI tax on entertainment devices, calculated
on the difference between gross revenues and the amount due
to the local municipality. Ten percent of the resulting amount
constitutes ISI tax.
By contrast, the machine sector pays specific taxes for the
machine sector, including 12.7 percent on turnover for so-called
NewSlots (AWPs, etc.) and 5 percent of turnover on VLTs.
Remote Gambling
Revenues for online gaming operations have grown consistently
year-on-year since the regulation process began in 2006 and
Italy now has one of the largest gaming catalogues for remote
gambling activities in Europe, including betting on sports and
horseracing events, cash and tournament poker, lottery and
online casino games including online gaming machines.
In Italy every online gaming platform must be authorised
and licensed by ADM and meet the criteria for responsible
advertising and player protection.
Technical regulations for the operation of remote gambling
services dictate that operators must also facilitate players with
tools to self-exclude from gambling services, with the option
to establish a fixed or indefinite term of self-exclusion. The
list of players who decide to self-exclude from participating in
gambling services must be notified to ADM.
Land-based casinos that choose to operate also as online
platforms must be licensed by ADM as well, and meet the
same criteria for player protection as other online operators.
Land-based casino websites have links containing all the above
elements, plus links to the ADM website.
LITHUANIA
Currently only land-based gambling is regulated in

Lithuania and any form of online gambling is prohibited.
In Lithuania there are 17 casinos operated by four
licensees.
Draft gambling laws to regulate online gambling was
approved in its first reading by the Lithuanian parliament
in June 2012 but developments have since stalled.
The draft law also proposes to limit the number of
casinos to 20 and that online operators applying for a
licence would have to hold a land-based licence for at
least one casino, five horse race betting locations, ten slot
machines parlours or 20 betting or totalisator parlours.
The draft law also includes a proposal to give
the regulator the right to instruct internet service
providers (ISPs) to quickly block illegal operators
domain names when told by the regulator.
iauliai
Panevys
Klaipda
Kaunas
Vilnius
Lithuanias 17 casinos are located in 5

cities:
In Vilnius there are seven casinos: four
operated by the brand Olympic Casino
(licence holder Olympic Casino Group
Baltija, UAB); two by the brand Tornado
Casino (licence holder VSGA, UAB) and
one by the brand Nese Casino (licence
holder Nese, UAB)
In Kaunas there are three casinos: two
operated by Olympic Casino and one by
the brand Nautilus Casino (licence holder
Savas Kazino, UAB)
In Klaipda there are four casinos: one
operated by Olympic Casino, one by
Tornado casino and two more by Nese
Casino.
In iauliai there are two casinos: one
operated by Olympic Casino and the other
by Tornado Casino.
In Panevys the sole casino is operated by
Olympic Casino.
63

Market Data
Population
Currency
Litas (LTL)
GNI (Gross National

Income)
US$13,920 (World Bank 2012)

People
65.1 (World Bank 2011)
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
BBB+ with a stable outlook (Fitch 2013)
A smoking ban is in place in Lithuanian casinos.
Land-based operators have slowly started to recover in the

country after years of declining revenue, even as they have
struggled to compete with an unlicensed online market.
The proposed changes to the gambling law in the country

include legalising online gaming, legalising poker tournaments
outside casinos and introducing new games.
Gross gaming revenue (GGR) for Lithuanias 15 casinos has seen

modest growth in the last few years and in 2012 increased 8
percent to 27m.
Poker was branded a sport in 2010 and a commercial poker bill

was drawn up and registered in parliament in September of the
same year but the law has not yet been implemented.
The total gross gaming revenue for the 13 licensed operators in

Lithuania offering casino, gaming machines and sports betting
amounted to LTL208m (60m) in 2012. A total of 2,286 people
are employed at the 15 casinos in Lithuania.
Regulator
By law each casino in Lithuania must operate at least three

tables and 30 category A gambling machines.
Estonia-listed operator Olympic Casino Group had the biggest
market share in the country with gross gaming revenue
amounting to LTL63m (18m) last year. It has 12 venues in
Lithuania.
As online gambling is prohibited in the country there are no such

measurements in place yet.
Category B machines have limited winnings and stakes and are

not permitted in casinos but in gaming halls around the country.
A minimum of ten machines must be installed in the halls. There
is an age limit of 18 years to gamble on the machines.
Taxation
Remote Gambling
Taxation in Lithuania is based on a monthly fee per machine or

table in the casinos.
Online gambling is prohibited in the country but several draft

bills to regulate online gambling have been discussed by the
parliament.
The Lithuanian Casino Market
Casinos are the only premises that can offer Category A

gambling machines which offer unlimited winnings.
Category A machines: LTL800 (230) per machine per

month.
Category B machines: LTL300 (87) per machine per
month.
Roulette, card or dice tables: LTL6,000 (1,740) per table
per month.
In 2012, the licensed operators paid a total of 11m in gaming tax.
One bill that would regulate slots machines, table games and
online gambling was approved in the first reading in June last
year.
The regulator has also submitted draft proposals to the
government that would give it the right to block online firms
operating in the country illegally.
It is believed that the black market is significant in the country
but many operators have decided to pull out of Lithuania as part
of their moves away from grey dot.com markets.
The Gaming Control Authority (previously called the State

Gaming Control Commission) regulates all types of gambling
under the Ministry of Finance and is responsible for the
supervision and control of all gambling activity in the country.
There are no requirements for gambling operators to contribute
to good causes.
However, lotteries in the country have to allocate 8 percent of
the face value of tickets to sponsorships or charity.
Player Protection

There are around 3,500 gambling machines in Lithuania.
There are around 525 Category A machines which offer unlimited
winnings and are only permitted in casinos. A minimum of 30
machines are required in casinos.
The general age limit to gamble in Lithuania is 18 but to enter

a casino players have to be 21 years old and registration at the
casino entrance is required by law.
There is a self-exclusion programme in place introduced in 2004
and, by 2012, 2.668 people had added their name to the list.
An advertising ban applying to most gambling services is in
place, but unlicensed operators advertise in the country with
some facing legal proceedings as a consequence. Fines of up
to LTL25,000 (7,240) can be handed out by the regulator if the
advertising ban is broken.
Sponsorships are allowed as they are deemed to be different to
advertising.
As well as a licence from the government, operators need
permission from the relevant municipal council to set up a casino
in each district.
64
The Gaming Control Authority said in September 2013:

Recently, there has been an increase of websites that
are advertising foreign gambling operators in Lithuanian
language.
65
LUXEMBOURG
There is currently only one casino in Luxembourg: the

Casino 2000 in the municipality of Mondorf-les-Bains.
Luxembourg has a general ban on slot machines and
other types of gaming machines. Only the sole licensed
casino and Loterie Nationale are allowed to operate
such machines. The Loterie Nationale operates 150
video lottery terminals across the country with a game
called Zubito and Casino 2000 operates around 300 slot
machines.
The small territory of Luxembourg is attractive for
operators in neighbouring countries which have sited
a number of casinos and gaming halls just across its
borders.
12,000 more visitors came to the casino in 2012 than in
2011 with a total of 435,000 visits, but total revenues
declined to 47m from 50m a year before. Slot machine
gambling accounted for 43m of that figure.
In March 2012, six betting shops opened in Luxembourg
under an agreement between the national lottery
acting as a de facto regulator and the French horse race
betting monopoly PMU. Although PMU may offer online
gambling under the terms of its land-based licence, it has
so far limited its online activities to betting on terminals
installed in betting shops.
Casino 2000
Casino 2000 (in Mondorf-les-Bains)
The Loterie Nationale enjoys a monopoly over lotteries in

Luxembourg and is the only company currently offering
online gambling officially. Other German-based lotteries
have been tolerated.
Luxembourgs Government Council has held meetings
since 2012 with the Ministry of Justice to adopt a
consistent position in relation to online gambling. It is
expected that a law amending the 1977 Law and the 2009
Law could be adopted between 2013 and 2014.
67
Market Data
Casino customers showing signs of problem gambling
behaviour are approached by casino staff. A short self-test is
offered and general information on gaming addiction may be
given. Depending on the outcome, a limitation or a ban may be
recommended to the customer.
Population
531,000 in 2012 (World Bank Data)
Currency
Euro
GNI (Gross National

Income)

People
Taxation
Mobile Phone
Subscribers Per 100
People
In 2012 Luxembourgs sole casino paid gaming taxes of 22m,

an 8.3 percent drop on the 24m contributed a year before.
Doing Business
Ranking

Bank)
Credit Rating
AAA, Fitch 2013
The Luxembourg Casino Market
Luxembourgs Licensed Casino Market
Regulation
Gaming Machines
Gambling in Luxembourg comes under the supervision of the

Ministry of Justice and the Ministry of Finance, and gaming police
officers and officers of the Tax Administration supervise casino
property.
With the exception of video lottery terminals operated by the

Loterie Nationale, and the slot machines of its sole casino,
Luxembourg has an absolute ban on slot machines or any other
type of gaming machines.
Casinos, along with a limited amount of video lottery terminals,

sports betting and lottery, are the only forms of gambling that
are exempt from Luxembourgs broadly prohibitive Gaming Act
1977. The same Gaming Act requires that casinos be land-based
and be established with the intent of promoting tourism.
Poker
A decision to issue additional casino licences can be made by

the Council of Ministers, but authorised casinos must restrict
their operations to approved land-based games, with no online
activities available.
According to Article 6 of the Gaming Act 1977, stud poker can be

provided in casinos.
A very detailed list of games that may be offered by casinos,

and their applicable rules, was last updated and modified by
regulation on March 8, 2002, the last update of the gaming
regulations in Luxembourg.
Casino 2000 supports a project Vision4Children (http://www.

vision4children.com/) that has been chosen by shareholders and
employees of the casino. This organisation collects money for
different projects; for example, the education of children in India.
There are progressive gaming tax rates starting at 10 percent and

rising to 80 percent based on defined levels of GGR.
Remote Gambling
Currently the only officially licensed entity able to provide online
games in Luxembourg is the Loterie Nationale, and no other
authorisation has been issued to any private online gaming
operator.
According to the Ministry of Justice, a licence may be issued
to private operators that offer online games to Luxembourg
residents. However, the ministry has indicated that online
gaming supply should be demand-based and not based on
possible revenues. It is possible that a law amending restrictions
on online gambling could be adopted between 2013 and 2014.
The tax regime stipulates that the direct recipient of

gaming taxes is the Grand Duchy of Luxembourg, although
municipalities where a casino is located receive 20 percent of all
gaming taxes.
At present, there is only one casino, so only the Municipality of
Mondorf-les-Bains, a commune of 4,500 people, receives this
revenue.
A gentlemans agreement was signed in 2007 between poker

organisers and the Ministry of Justice enabling poker events to
be organised if the stakes paid by players remain low (20-50).
The casinos project is staffed by casino employees. On different

occasions the casino helps to support their activities.
Casino 2000 is also a sponsor of local clubs and of the national
Olympic Committee, COSL.

National legislation requires customers to be a minimum age of
18 to participate in casino gambling in Luxembourg.
Player protection measures demand that players must be able to
self-exclude, or to place a limit on the number of casino visits.
In 2002 Casino 2000 installed a pro-active player protection
programme, with regular education of all involved employees. A
team of seven floor managers is in charge of this programme.
68
69
NETHERLANDS
As tough economic conditions and competition from

arcades and online gambling had their effects, revenues
and visitation, as well as the jobs created and taxes paid
to the state by monopoly operator Holland Casino, all
declined in 2012 when compared to a year before.
Total gaming revenues at Holland Casinos 14
properties declined 3.4 percent year-on-year from
526m to 508m in 2012, as slot revenues stayed
flat and table game win slumped 6.6 percent.
Players made more than 100,000 fewer visits to Holland
Casino venues in 2012, and the monopoly operator shed
nearly 300 jobs across its properties.
According to the Jansen Commission report from August
2010, more than one million Dutch citizens participated
in illegal games of chance and more than 565,000 of
those people participated in online gambling. In the
process they spent 181m per year.
Leeuwarden Groningen
Zandvoort
Amsterdam
Scheveningen Schiphol
Enschede
Utrecht
Rotterdam
Breda
Eindhoven
Nijmegen
Venlo
Valkenburg
Holland Casino operates 14 casinos in

Amsterdam, Breda, Eindhoven, Enschede,
Groningen, Leeuwarden, Nijmegen,
Rotterdam, Scheveningen, Schiphol
Airport (for air passengers only), Utrecht,
Valkenburg, Venlo and Zandvoort.
71
Market Data
Population
16.69m (2011) World Bank Data
Currency
Euro
GNI (Gross National

Income)
$49,660 (2011) World Bank Data

People
92.3 (2011) World Bank Data
Mobile Phone
Subscribers Per 100
People
115 (2010) World Bank Data
Doing Business
Ranking

Bank)
Credit Rating
The Dutch Casino Market

Regulator
The Dutch Gaming Authority, an independent supervisory body, is
responsible for the regulation and control of the gambling market
in the Netherlands, as well as for the licensing of operators.
The Dutch Gaming Authority was installed on April 1, 2012,
financed through contributions and levies from the gambling
operators. Responsibility for gambling policy lies with the
Ministry of Security & Justice.
The watchdog is tasked with close cooperation with foreign
regulators and acts as a knowledge centre for the public and
authorities like addiction care centres.
In terms of enforcement measures, the authority is able to
impose administrative fines of up to 760,000, or 10 percent of
the companys turnover. Multiple fines for the same offence may
be given in certain circumstances.
The Netherlands Licensed Casino Market

On December 17, 1975 the only casino licence in the Netherlands
was formally awarded for an indefinite period of time to
De Nationale Stichting tot Exploitatie van Casinospelen in
Nederland, the official statutory name of Holland Casino. Holland
Casino opened its first casino in Zandvoort in October 1976.
Subsequently another 13 casinos were opened in Amsterdam,
Breda, Eindhoven, Enschede, Groningen, Leeuwarden,
72
Online operators continue to offer their services without

a licence, build their databases. Its completely unfair
competition. Ron Goudsmit, senior vice president of
international development at Holland Casino.
Poker
AAA, March 15, 2013, Fitch
Nijmegen, Rotterdam, Scheveningen, Schiphol Airport (for air

passengers only), Utrecht, Valkenburg and Venlo.
Dutch gambling law is restrictive in nature but past governments
have received serious setbacks to this policy. First, the European
Commission instigated infringement proceedings regarding
the monopoly on sports betting in 2006. The Dutch Senate
also rejected the proposal for a new state monopoly on online
gambling in April 2008.
In March 2011, the Dutch government announced its plans to
grant licences for internet gambling in the Netherlands after
conceding that hundreds of thousands of Dutch gamblers ignore
the restrictions every year.
Online gambling licences were expected to be available by 2014.
However, this reform was pushed back when, in April 2012, the
Dutch Prime Minister Mark Rutte and his cabinet resigned.
Besides regular poker, new games like Casino War, Ultimate

Texas Holdem Poker and 4 Card Poker have been made
available in Holland Casinos as of June 2013, following an
amending decision to the Casino Games and Game Rules 2000.
Holland Casino seeks to play a positive and responsible role in
society.
Corporate social responsibility forms an integral part of the
Holland Casino policy and each department contributes to the
overall CSR ambition.
This strategy is based on seven CSR spearheads, both with a
short and long-term ambition.
Main points are:

Safe and responsible game mix.

Corporate integrity.
Open communication.
Responsible employer.
Involvement with society.
Sustainable procurement.
Sustainable casinos.
New elections resulted in a coalition government, headed by the

VVD, the centre-right party, closely followed by the Labour Party
which was officially formed on November 5, 2012.

A safe and responsible gaming offering by Holland Casino
does not stand isolated from other objectives and the firm
consistently reviews its efforts in relation to other areas.
This new Dutch liberal-labour coalition government signed an

agreement in October 2012 to modernise the online gambling
industry over the next four years and to restrict illegal activities
setting up a licensing framework.
Holland Casino is a company with its focus on people, which

is manifest in the companys safe and responsible game mix.
Holland Casino strives to offer guests a great night out and to
reduce the risks of the game in safe surroundings.
The coalition agreement also reaffirmed the governments

intention to privatise Holland Casino, the Dutch monopoly for
the operation of land-based casinos.
Gaming must be offered in a fair and impeccable manner,

gaming equipment should be in order and guests should feel
safe and secure when visiting one of the Holland Casinos.
In May 22, 2013, state secretary of security and justice Fred

Teeven revealed the long-awaited government plans for
regulating online gambling.
Open communication entails regular consultation with relevant

stakeholders about their expectations regarding safe and
responsible gaming.
Under the proposed bill, unlimited licences would become

available for a wide range of online games. In accordance with
the governments high priority of addiction prevention, the
billestablishes strict rules and conditions to prevent addiction
and fraud and ensure effective supervision of compliance.
Holland Casino values their views and shares relevant

information and opinions to encourage further development of
the policy.
The games covered by the bill are poker, casino games, slot
machine games and sport bets (fixed odds, exchange betting
or pari-mutuel betting, live betting), and the measure proposes
a tax rate for online of 20 percent, lower than the 29 percent
currently paid by casinos and arcades.
Holland Casino employs more than 4,000 people and seeks to

be a responsible and well-liked employer.
The staff are also actively involved in the local environment.
Using the lost and found funds made available by Holland
Casino they support various local and national charities.
The procurement office deals with the suppliers whereby

sustainability is taken to heart when buying all sorts of products,
taking into account human and environmental interests.
Human and environmental issues are also the two focal points
when it comes to the administration of the properties.
Holland Casino reports on the basis of the Breeam methodology
and consideration given to the CO2 footprint helps to improve
the energy savings plan.
Facts and Figures

Holland Casino employs more than 4,000 men and

women throughout all regions in the Netherlands.
The majority of Holland Casinos staff are employed under
a collective agreement.
Total staff compensation including social security costs
was 237m in 2012.
Total training time in 2012 was 43.085 hours.
Holland Casino pays more than 140m in gaming tax
alone.
Holland Casino is a major buyer of goods and services
on local, national and European level, creating numerous
direct and indirect jobs in different industries.
Every year Holland Casino has reduced its total CO2
footprint, which fell to the level of just over 21 tons in 2012.

Enabling just one single casino licence was a deliberate choice
made by the Dutch government. Channelling casino gaming via
only one licensee was meant to guarantee a legal, trustworthy
and well-controlled gaming offering.
On the basis of the gaming law statute Holland Casino runs an
intensive responsible gambling policy, not just as a consequence
of the official rules but also because Holland Casino as a
company truly feels a social responsibility. The policy is aimed
at monitoring Holland Casinos guests, recognising problematic
behaviour, taking preventive measures and providing active
intervention and referral to addiction prevention agencies for
guests showing true problematic behaviour.
To make the policy work all staff are trained by experts from
gambling addiction agencies. Training courses are given on
different levels. There is a base training for all staff, a training
course for managers who do the host/prevention interviews and
advanced training for all security and legal staff.
National legislation in Holland requires all customers to be 18
years of age.
Taxation
Changes to the Dutch gaming tax regime in July 2008 effectively
doubled the tax rate for slot machine income, while slightly
lowering the tax for table games. Tax revenues in Holland from
casino gaming peaked in 2007 and have declined ever since.
73
POLAND
There are currently 43 casinos in Poland authorised to

offer casino games including roulette, card games and
slot machines.
After reaching a peak in 2007, revenues dropped for
several years before climbing 15 percent in 2012 to 77m.
By the current law in the Netherlands, an operator located in

the country providing offline casino games, slot machines and
all online games is liable to a gambling tax of 29 percent of its
gross gaming revenues (GGR) (difference between the stakes
received and the prizes awarded to the participants).
If a Dutch player plays online on a website based outside the
Netherlands, the player is liable to a 29 percent tax based on
gross earnings per month.
Remote Gambling
The draft new online gambling law underwent public
consultation, which ended on July 21, 2013 with 49 responses
submitted.
The draft bill will next go to the Council of State, the Parliament
and the Senate, which should ultimately lead to the legalisation
and start of online at the beginning of 2015.
There will be no limit as to the number of licences and all games
will be offered. A central database will be set up in which all
players will be registered who are banned from land-based
casinos, arcades or online operations.
Final details of the bill are still under discussion and the
major hurdle will be the proposed difference in gaming tax
between land-based and online. However, the government has
maintained that a low-level of taxation for online gambling is
essential to dissuade people from turning to illegal providers.
Slot machines based outside casinos were banned in

2010 when new legislation was implemented but gaming
halls are still operating on long-term licences that will
expire at the end of 2015. The ban is, however, still being
analysed by the Polish courts to establish if it is legal or
not.
The Jansen Commission Report
In 2009 Dutch Ministry of Justice created an advisory
committee, known as the Jansen Commission, to
address the question as to whether the Netherlands
should regulate online gambling.
The Jansen report of 2010 found that the illegal market is
dominated by poker.
Online gambling by game frequency variant
(percentage)
Poker - 66
Other casino games - 13
Gaming machines - 10
Sports betting - 4
Toto - 4
Bingo - 2
Other/various/vague - 26
Slot machines including those in arcades generated the

largest turnover in Poland in 2012 at 131m, a decrease on
the 2011 figure according to Ministry of Finance analysis.
Amendments to the Gambling Act in 2011 allowed for
online gambling for the first time and, in 2012, Fortuna
was the first operator to be granted an online licence to
offer sports betting.
Draft gambling law amendments were submitted to the
parliament in June 2013 which would also permit online
lotteries. The draft is planned to come into force in
January 2014.
The number of casinos in Poland increased

dramatically in 2012, with ten new casinos
being opened.
Source: Jansen Commission report August 2010

Illegality research conducted by Regiopla
The current gaming tax for land-based operations is 29 percent

and the proposal for online is 20 percent, a differential taxation
proposal which has drawn strong objections from Dutch casinos
and arcades.
74
75

Market Data
Population
38.5m (World Bank Data 2012
Currency
Polish zloty
GNI (Gross National

Income)
12,660 (World Bank 2012)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
A- with a stable outlook (Fitch 2013)
The Polish Casino Market

After four years of declining revenues, the casinos in Poland saw
a double digit increase in 2012, reaching 77m.
The number of casinos increased dramatically in 2012, with ten
new venues being opened bringing the total number to 43.
Among the licensees are Olympic Entertainment Group, Orbis
Casino Group and Casinos Poland.
Casinos in Poland have historically been adjacent or included in
hotel developments and have, as a result, been smaller rather
than larger.
Casinos are also permitted on Polish flagged ferries or
passenger ships as long as the gambling starts and finishes 30
minutes from the port.
In towns or cities with fewer than 250,000 people, only one

casino can be accommodated.
With a larger population than 250,000, an extra casino is
allowed for each subsequent 250,000 inhabitants. The total
number of casinos in one single province is one for each
650,000 people.
76
Online gambling is taxed at 12 percent of turnover.

Poker
Only poker tournaments with at least ten registered players are
allowed in casinos and a special permission for organising the
tournaments is needed.
There are no statutory requirements for casino operators to

contribute to good causes but usually operators are involved in
supporting charitable events.
There are no other statutory requirements of player protection.

There is an age limit of 18 to gamble online. A player has to
have a local bank account to register with one of the licensed
operators.
Taxation
Casino games and slot machines are taxed at 50 percent of
gross gaming revenue. In 2012, 29m was paid in tax by the 43
casino operators.
The Polish Gambling Act was amended in July 2011 to allow

online sports betting and totalisator betting for the first time.
All other types of online gambling is prohibited and casino
operators are not allowed to offer their games online.
In January 2012, Fortuna became the first operator to get a
licence to legally offer sports betting online. Three other
operators have since been granted an online licence.
But the 12 percent turnover tax has received a lot of criticism
from operators claiming it has pushed many punters towards
unlicensed operators and slowed down the operators growth,
both online and offline.
Fortunas marketing director Vladan Crha said: Were
trying to discuss a potential change of taxation or a
more strict approach to the illegal operators in the Polish
market but we cant see a major change happening this
year.
It is prohibited to advertise or promote casino games and

anyone caught doing so will be imposed with a fine. Casino
operators are also banned from sponsoring.
A smoking ban was introduced in 2010 but casinos are allowed

to have designated smoking rooms on the premises.
Remote Gambling
The Ministry of Finance is the authority that issues licences and

regulates and supervises the gambling market in Poland.
There is an age limit of 18 to participate in gambling in Poland,

with the exception of promotional and raffle lotteries.
The number of visitors to the 43 casinos dropped 3 percent in

2012 to 560,000.
Each casino is now allowed 70 slot machines, an increase from

30 permitted before the Gambling Act came into force in 2010.
Regulator
Player Protection
2,000 people are employed in Polands casinos.
In 2011 and 2012, slot machines generated the largest turnover

in the country, followed by number games and casino games.
In 2012, the revenue from slot machines, including those in
arcades, amounted to 131m.
A casino licence in Poland is valid for six years.
Only the state-owned lottery is required to earmark some of

the money raised for cultural and social projects and problem
gambling.
To operate a casino in Poland, a company is required to be a joint

stock company or a limited liability company, have a registered
office in the country and have minimum level of share capital of
PLN4m (985,000).
The case is still going through the courts in Poland and has now
been referred to the Polish Constitutional Court after several
diverse judgments from district courts in the country.
Plans to introduce blocking of illegal websites were dropped

after the draft law received a detailed opinion from the European
Commission and Malta.

The Gambling Act in 2009 was adopted swiftly and without
notifying the European Commission in 2010 amid a corruption
scandal and, among other important provisions, banned slot
machines outside casinos.
There is, however, a payment ban in place that blocks payments

to unlicensed websites.
Online operators are allowed to advertise their games on their
websites.
However, existing licensed slot halls were allowed to operate

until the six-year licences expire and will be phased out by the
end of 2015.
The ban was challenged by the industry before the Court of
Justice of the European Union, which ruled in July 2012 that the
acts validity was questionable due to the lack of notification
to the commission. But the court left the final decision to the
national courts.
Bartosz Andruszaniec, lawyer at Allen & Overy in Poland,
said last year: This judgment does not result in invalidity
of the entire law but there will be valid questions as to
whether a set of other provisions of the law should have
been qualified as technical provisions and notified.
77
PORTUGAL
The 2008 European economic crisis has decimated

Portugals land-based casinos industry and the countrys
11 casinos saw their revenues plunge continuously from
2008 to the present. Total revenues of 290m were down
11 percent on 2011, with the cumulative revenue decline
from 2008 to the first half of 2013 topping 34 percent,
according to data collected by the Portuguese Casino
Association from all operators.
In late April 2011 Portugal was forced to request a 78bn
bailout from the International Monetary Fund and
European Union member states. In 2012 real GDP shrank
by 3.2 percent. In 2013 Portugals economy has continued
to contract.
6,500,000 visitors came to Portugals casinos in 2012,
nearly 10 percent down on 2011 and some 30 percent
fewer than the 9,000,000 that came in 2010.
Although casino gaming tax payments fell nearly 7
percent in 2012 to 140m, the relative taxation burden on
operators has continued to increase.
In the first quarter of 2013, Portugals casinos announced
they would stop paying as much as 10m in monthly tax
as a last resort to force the government to re-think the
12 year-old casino concessions with their taxation system
where tax levels rise as revenues fall, an unsustainable
situation which has aggravated the effects of Portugals
deepening recession.
A new inter-ministerial study on land-based and online
gambling regulation was concluded in April 2012 and may
result in online gambling being taxed and regulated.
Casino Povoa de Varzim
Hotel Casino Chaves
Casino Espinho
Casino Figueira da Foz
Casino Estoril
Casino Lisboa
Casino de Troia
Hotel Algarve Casino
Casino de Monte Gordo

Casino de Vilamoura
Casino da Madeira
The 11 casinos in operation in Portugal are:

Casino Estoril.
Casino Lisboa.
Casino Povoa de Varzim.
Casino de Espinho.
Casino de Vilamoura.
Casino Figueira da Foz.
Casino da Madeira (Funchal).
Hotel Algarve Casino.
Casino de Monte Gordo.
Hotel Casino Chaves.
Casino de Troia.
79

Market Data
Population
10.5m in 2012 (World Bank)
Currency
Euro
GNI (Gross National

Income)
US$20,580 in 2012 (World Bank)

People
64 in 2012 (World Bank)
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
Standard & Poors: BB with a negative outlook,

as of March 2013.
Poker
Poker is considered a game of chance and therefore it can

only be run at casinos. This includes both cash games and
tournaments. Poker is increasingly popular in Portugal
and Portuguese casinos have staged several international
tournaments. However, these are increasingly difficult to
organise as the gaming authorities enforce legislation that
forbids filming or the photographing or players. Also the lack
of regulation for online gaming prevents casinos from running
online tournament qualifiers.
Currently no player protection training is required by law in

Portugal.

As a part of their remit to develop and encourage tourism,
casinos in Portugal have to spend at least 3 percent of their
gross gaming revenues on cultural activities, tourism promotion
and entertainment within their respective gaming zone.
The law obliges casinos to organise entertainment offerings and
programs with high artistic values.
The Portuguese Casino Market

Regulator
The supervisory agency for gambling and games of chance
in Portugal is the Servio de Inspeco de Jogos - Turismo de
Portugal, previously known as the Inspectorate-General for
Gaming and Betting.
The activities of the lottery operator Santa Casa are separately
reviewed by the Ministry of Employment and Social Security.
Land-based casinos are allowed through specific concessions
granted by the state, as well as bingo, which can be operated
within a casino or outside. Slot machines are authorised only
within casino venues. The possibility of operating slots within
other specific gambling venues depends on regulation that has
not yet been approved.
In 2011 some minor changes to the Gaming Law amended
administrative requirements for amusement games (specifically
contests, raffles and amusement machines) But, in general, the
legal framework dates from the 1980s and still requires thorough
updating.
Two studies by different Inter-ministerial Commissions,

conducted in 2010 and most recently in 2012 have proposed
legislation and measures to restructure casino regulations and
introduce online licensing but no changes have so far been
adopted.
Portugals Licensed Casino Market
Casinos are regulated in Portugal and are restricted to gambling
zones defined by the law. The designated gambling areas are:
Aores, Algarve, Espinho, Estoril, Figueira da Foz, Funchal,
(Madeira) Porto Santo, Pvoa de Varzim, Tria and VidagoPedras Salgadas (Chaves).
Currently, there are 11 casinos in Portugal, with four operators
Estoril, Solverde, Amorim Turismo and Pestana.The gaming
areas of Aores and Porto Santo have been subject to franchises
but the casinos are not operating. The former includes a casino
on the island of So Miguel, and the latter allows for another
casino on a smaller island near Madeira.
Estoril Sol, which operates Casino Estoril, Casino da Pvoa and
Casino Lisboa, controlled 64 percent of the casino market in
2012. Solverde operates Espinho, Chaves, in the Vidago area,
and the three casinos in Algarve. Amorim Turismo runs Figueira
and Tria, while Pestana operates Madeira (Funchal).
Beyond the land-based casino market, Santa Casa da
Misericrdia de Lisboa dominates the gambling industry in
Portugal.
The charitable organisation was granted a monopoly for the
sale of lottery and sports-betting products as well as being the
only entity authorised to provide remote gambling in Portugal,
although this authorisation is restricted to the games Santa Casa
already runs on a live basis.
Portugal has licensed casinos and bingo operators. Revenues of
land-based casinos have fallen during recent years as a result of
the countrys economic downturn and competition from offshore
online operators.
80
60 percent of the annual budget of Turismo de Portugal, for

tourism financing, is supported by annual fees paid by casinos.
The beneficiaries of casino contributions are projects with
touristic interest, namely, museums, sports halls, golf courses,
hotels, marinas and concert halls.
Gambling in Portugal is considered an atypical and sensitive
economic activity, which must be closely monitored to prevent
organised crime and money laundering.
Under national legislation people under 18 years of age are
prohibited from entering casinos gaming areas.
Casinos can be open to the public for up to 12 hours per day.
Any customer can ask to be barred from entering casinos
gaming areas for up to five years.
The Inspectorate-General for Gaming and Betting can prohibit
any individuals access to gambling venues. Such prohibition
can be carried out by demand of the operator, or by the
Inspectorate-General or on the request of the player.
Although not mandatory, Portugals casinos have adopted

player protection measures which include the provision of
information booklets on problem gambling, and the assessment
of potential problem gamblers by casino management and
supervisors.
Taxation
The so-called Special Gaming Tax is set by the gaming law
and has to be paid each month both for table games and
slot machines. Despite intricate methods of calculation and
escalation mechanisms during the period of each franchise,
gaming tax is not calculated on actual revenue, but on what the
law considers to be the initial capital of table games and slots.
What defines the final amounts to be paid to the government
are the annual fees established in the franchise agreements.
These are equal to 50 percent of gross gaming revenues in the
franchises of Estoril (Casinos Estoril and Lisboa) Pvoa and
Espinho, 35 percent for the three casinos in Algarve, and 30
percent for Figueira. In all cases the franchise agreements allow
for the gaming tax to be offset against the annual fee.
The other franchises - Madeira, Vidago (Chaves) and Tria are
subject to franchises in which the contractual obligations add
up to Gaming Tax. The overall tax burden in these casinos can
range from 17 to 25 percent of GGR.
Portuguese casinos whose franchises date from 2001 are
subject to a minimum annual fee set for the first year, which
increases over the lifetime of the concession, at annual real rates
(additional to the inflation rate) ranging from 2.0 to 2.6 percent,
regardless of revenues.
As Portugals economy has sunk into a double-dip recession
and consumer spending has been squeezed, some casinos
have been faced with tax bills that rise in percentage terms as
their revenues go down, tending to exceed their entire gaming
revenues within some years.
If an exclusion is deemed to be preventive it will remain in

operation for a maximum period of two years.
Smoking Ban
Portugal established a smoking ban in 2007, under which
casinos have to define non-smoking areas of at least one-third of
the entire casino floor area. Additionally one-third of all gaming
equipment has to be located in the non-smoking area.
However, in early January 2012 the health secretary, Fernando
Leal da Costa, announced that the government aims to
strengthen the smoking ban even further.
According to the secretary, the government plans to diminish
smoking in public and enclosed places to restrict the exposure
that bar, restaurant and casino employees have to cigar smoke.
This taxation system has been the subject of justified complaints

from casino operators.
81
ROMANIA
Aiming to rebalance the concession contracts operators initiated
legal claims against the Portuguese government in early 2013.
Concessionaires also announced that they would stop tax
payments while the courts are assessing this case, although
they indicated they would provide guarantees for the missed
payments which could be as high as 10m a month.
Subsequent to the complaint the casinos made all outstanding
payments and resumed regular fulfilment of subsequent bills,
as conversations with the government started. The legal claim
against the government was also suspended.
The casinos are not happy with recourse against the
state, but the sustainability of their businesses is at stake.
Its not that we dont want to pay the charges, but this
situation is unsustainable as it is, said Jorge Armindo,
president of the Portuguese Casino Association.
VLTs and Slots
Gaming machines can be operated only in casinos and in
gambling venues. As of 2011, there were around 6,000 slot
machines in Portugal in legal casinos.
The Special Gaming Tax is also applicable to gaming machines.
In 2011 some minor changes to the Gaming Law amended
administrative requirements for amusement games.
Remote Gambling
There is currently no licensing system for online gambling in
Portugal, and Santa Casa, the monopoly lottery operator, is the
only entity authorised to provide remote gambling in Portugal.
This authorisation is restricted to the games Santa Casa already
runs on a live basis.
Portuguese Professional Football League in 2005. The socalled Santa Casa decision strongly supported Portugals
gambling policy, stating that the mere fact that an online
gambling operator is licensed in a given member state does not
automatically entitle it to operate in other member states.
A former CJEU ruling (Anomar, September 2003) had already
considered that, although susceptible to restrict the freedom
to provide services, Portuguese casino legislation that restricts
gaming to a limited number of franchise contracts is in
accordance with the EU Treaties, in view of the concerns of social
policy and the prevention of fraud which justify it.
Still, unlicensed operators continue to explore the Portuguese
online market and, as a result of practical and economic
considerations, Portugal may be encouraged to regulate its
remote gambling market to obtain more revenues.
A new inter-ministerial study on land-based and online gambling
regulation was concluded in April 2012 and delivered to the
Prime Minister.
According to this report, three regulatory models were
proposed, and the study recommended the semi-liberal model,
under which casinos would be allowed to run their games online
and Santa Casa would maintain the right to run sports betting
and lottery games online. Race betting would be subject to a
special regime. However, fixed odds sports betting would also
be open to private operators.
With regard to taxation, the inter-ministerial report suggested
remote gambling to have a taxation system based on GGR.
The government is still assessing this report and conclusions
could be known by the end of 2013.
A combination of onerous new regulations, increased

taxes and economic turmoil has battered Romanias landbased gaming market since 2009.
Plagued with fewer customer visits and lower spending
for the past few years, Romanias remaining casinos saw
their revenues plummet again by nearly half in 2012 to
just 40m.
There are now just nine casinos in Romania, compared to
the 20 that existed in 2010, following a spate of closures.
Just 500,000 customer visits were made to casinos last
year, down from 1.1m in 2010.
Bucharest
Table revenues fell by 43.5 percent in 2012, but revenue

from slot machines was all but wiped out as win fell from
15m to just 4m.
At the same time fees and taxes rose 90
percent, even as outlets were closing, to 703m
Romanian leu (124m), between 2008 and 2011.
Although online gambling is regulated in Romania no
operators have yet applied for licences because of the
prohibitively high rates of taxation.
Romanias Competition Council investigated alleged
anti-competitive and illegal operations within Loteria
Romana in November 2012, and it was confirmed that the
European Commission had asked the council to provide
details regarding the contract between Loteria Romana
and Intralot.
Bucharest
Athenee Palace Hilton
Casino Bucharest
Casino Mirage
Grand Casino
Grand Casino Romania
JW Marriott Bucharest Grand Hotel
Princess Casinos
Queen Casino
Viva Casinos
In a landmark decision handed down in September 2009 the

Court of Justice of the European Union (CJEU) ruled that the
freedom to provide services, set in the EC Treaty, does not
preclude the Portuguese legislation from prohibiting operators,
established in other member states, from offering games of
chance via the internet within the territory of Portugal. The CJEU
further considered that the organisation and functioning of Santa
Casa perused objectives in the public interest, namely protecting
customers against fraud.
The case was the result of legal steps taken by Santa Casa and
the Portuguese casinos against the Gibraltar-based operator
Bwin which had been offering remote gambling in Portugal
without a licence and, in order to publicise this unlicensed
activity, had signed a 10m four-year sponsorship deal with
82
83

Market Data
Population
21.38m (World Bank Data)
Currency
Romanian leu
The Romanian Austrian Casino Corp. is a sponsor/participating

operator.
State-owned company Loteria Romana holds a licence, in

addition to approximately 400 other operators.
GNI (Gross National

Income)

People
Slot machine licence applicants must have a minimum capital of

RON30,000 (approximately 6,900) on the date of application
to be eligible for a licence.
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
BBB- (Fitch, April 2013)
The Romanian Casino Market

Economic Situation
to include background checks on key individuals; increased fees

and required share capital; and the introduction of additional
technical standards.
Romania has suffered severely from the economic downturn

across the eurozone since 2008. In 2012 the country accepted a
500m instalment of a 3.4bn precautionary loan offered to it
by the International Monetary Fund (IMF) in March 2011.
Each casino operator within the city of Bucharest is now required

to have a minimum of: 12 gaming tables of which at least two are
roulette tables. Outside the capital the minimum number is ten
gaming tables, of which at least two must be roulette tables.
Although the IMF, in a review, estimated economic growth of 2.5

percent in 2011, lower levels of growth followed in 2012.
Each gaming floor must be equipped with emergency lighting

and emergency exit doors, and a fire extinguishing system,
along with adequate staff rooms, and back of house services. All
gambling equipment, such as dice and cards, must comply with
internationally accepted standards.
Regulator
The Gambling Authorisation Commission was removed from the
control of the Ministry of Finance in 2013, and a new National
Office for Gaming (NOG) was set up under direct government
control beginning operations on April 15, 2013.
The new NOG has increased powers to regulate, monitor,
control and authorise all forms of gaming in Romania.
The NOG has set up a Consultative Council where
representatives of private gaming operators can discuss
improvements to legislation and procedure.
These are all positive developments and show an increasing
maturity in the Romanian gaming market after a long period of
turmoil.
Romania has one of the most extensive gambling markets in
south-eastern Europe, but the sector has contracted sharply
since 2009 as the government sought to consolidate, tax and
regulate the market in the midst of an unprecedented economic
downturn.
The number of casinos has fallen from 22 in 2009 to just nine in
2012, while sports-betting outlets declined to 14 from 26 over the
same period, according to the Romanian Gaming Association of
Organisers and Producers.
Romanias Licensed Casino Market
As a part of the introduction of regulation in 2009 Romania
tightened its licensing requirements, introducing a dual licensing
framework consisting of both licences and authorisations for
every gambling activity. The rules extended probity requirements
84
All casinos must be equipped with a digital video surveillance

and recording system, and recordings need to be maintained for
a minimum of 30 calendar days. Operators must also maintain
customer identification records for at least five years.
Each casino operator must hold both a licence to organise
gambling and an authorisation to operate casino-style games,
with a separate authorisation required for each casino premises.
Licences are valid for a period of five years and are subject to an
annual fee of RON400,000 (approximately 92,000), more than
double their pre-2010 cost.
Poker
In April 2011, poker was officially recognised as a sport in
Romania. The Romanian Poker Federation was created to
organise the sector in the country. Operators holding a licence
and an authorisation to organise gambling and operate casinostyle games can organise poker tournaments.
Romanian gaming laws do not provide for specific player

protection measures; however, national legislation requires that
all visitors to casinos are aged 18 or above.
Each visitor must be registered in a computerised database and
must present a valid ID document.
Every visitor to a casino must pay a RON20 entrance tax which is
put toward the state budget.
Smoking Ban
Romania has a partial ban on smoking, with total bans only
in place on public transport and at healthcare facilities. For
hospitality venues which are smaller than 100 square metres,
smoking may be permitted. In larger hospitality venues, among
other places, enclosed ventilated smoking rooms are permitted.
Taxation
The combination of taxes and licensing fees makes
Romania an uncompetitive tourist destination for
gambling, and discourages investment in the gambling
sector, said Cristian Pascu, executive president of
the Romanian Gaming Association of Organisers and
Producers.
An authorisation to operate slot machines is subject to an annual

fee of 1,950 per slot machine.
Slot machine operators must hold both a licence to organise gambling
games and an authorisation to operate slot machine games. A
licence to organise slot machines is subject to an annual fee of
RON25,000 (approximately 5,750) and is valid for a period of
five years.
Remote Gambling
The regulations that legalise online gaming have been in
place for two years but no operators have as yet applied for a
licence due to the requirement in the Romanian Fiscal Code
to tax customers 25 percent of their winnings, and because a
monitoring company, needed to implement regulation, had not
yet been licensed.
Further political turmoil in the country in 2012 meant that the
creation of an online monitoring operator was delayed.
Efforts are underway to remove the tax on customer winnings
which would clear the way for licensed online gaming in
Romania.
New gambling tax rates came into effect on July 1, 2010,

introducing a tax of 25 percent of all player winnings in excess of
RON600 (135) per day.
The current gaming law is currently undergoing revision and it

may be that an online operator will require a land-based licence
before being issued a licence for online gambling.
The annual tax for each gaming table in Bucharest is now

RON250,000 (56,000) and RON120,000 (27,000) for tables
outside the capital.
Still, following the publication of the European Commissions

Communication on the European online gambling market in
October 2012, it is likely there will be further scrutiny applied to
Romanias online gambling framework from Brussels.
Taxes on slot machines and bingo games more than doubled

from their pre-2010 levels from 3,500 (790) lei per machine to
8,000 lei (1,800).
Additionally the standard corporate income tax or profits tax
applying to casino operators in Romania is 16 percent.
VLTs and Slots
If used in casinos, slot machines require a licence separate from
the casino licence, and each organiser must intend to operate at
least 50 slot machines in either a single or multiple venues.

The dire financial situations of many operators and the
excessively high taxation levels facing casino operators in
Romania makes sponsorship of good causes unfeasible at the
present time.
Nevertheless, the local Slots Association has established a
Problem Gambling help line that is funded by sponsorship
fees from individual operators, and a free helpline number is
advertised at the premises of each participating operator.
85
SERBIA
Total revenues at Serbias two licensed casinos fell

7.5 percent in 2012, compounding a 26 percent plunge
between 2010 and 2011. (Revenue data is only available for
Grand Casino Beograd.)
Table game revenues fell 12.6 percent, while slots
slumped 2.4 percent and the number of jobs created fell
3.8 percent to 356.
Grand Casino Beograd
Gaming tax of 1.2m paid in 2012 is now close to just half

of the 2.1m that the casino contributed in 2010 due to a
decline in total revenues and a change in taxation rules
for slot machines, in which the tax basis has changed
from Bill-in to Win figures.
Serbias gambling market has undergone rapid change
and transformation, but although Serbias new gambling
act entered into force in December 2011, a lack of
secondary legislation has meant that the implementation
of some of its most important provisions, including
remote gambling regulation and centralised slot machine
control, have been delayed.
Grand Casino Beograd is one of two

licensed casinos in Serbia.
87

Market Data
Population
Currency
Serbian dinar
GNI (Gross National

Income)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
BB- with a negative outlook from July 2013,

Fitch Ratings
Additionally, all player data is protected by law. All staff working

for the casino operators who have customer-facing roles are
required to be fully trained in the recognition of problem gambling
behaviour and the prevention of gambling addiction.
Leaflets addressing issues of gambling addiction, and featuring
the contact data of an institution certified by the Ministry of
Health for treating addiction, must be made available at each
counter or window where games of chance are played, and a
poster containing the same information must be displayed in the
vicinity of the entrance door.
National legislation requires customers to be a minimum 18 years
of age, with minors prohibited from entering any gambling facility.
Notices making it clear that minors are prohibited from gaming
must be displayed alongside all games.
The Serbian Casino Market

Regulator
Serbias Licensed Casino Market
In 2010 the Serbian government breached its contract with

Grand Casino Beograd by issuing another licence, within the
perimeter of 30km of central Belgrade, to a small operation
known as Fair Play Casino.
Grand Casino Beograd has established its reputation as a

respectable member of the community in which it operates
through many donations to childrens charities, culture and
sport.
Casino gambling is licensed for a ten-year term. Under the

2004 Games of Chance Act, the number of available casino
licences was limited to ten, although only two licences were ever
awarded under the act.
The list of beneficiaries have included Zemuns Veljko

Ramadanovic school for children with auditory impairments, the
Parks of Friendship humanitarian campaign mounted by the Our
Serbia non-governmental organisation and the You Can Do It
Too campaign launched by the Ana and Vlade Divac Foundation.
Personal Data Protection
The management of the company actively encourages its

employees to undertake humanitarian work and, independently
of the casino, the staff have raised funds for disadvantaged
children in Kosovo-Metohija. Grand Casino Beograd has
supported the Belgradization of Belgrade project and many
cultural events, such as the Belgrade Dance Festival and the
Belgrade Jazz Festival, as well as the National Theatre.
According to the provisions of the Serbian Law on Games of

chance, casino operators must ensure continuous audio and
video surveillance of all tables and slot machines, and the
entrance and exit of the property.
The Act on Games of Chance 2011 also requires a three-year

business plan and documents relating to the probity of officials,
proof of at least five years experience in operating casinos and a
schedule for the licence tax payments.
Although Grand Casino Beograd opened in June 2007, another
operator, Hit International, won a further tender for a second
casino licence in December 2006, permitting the operation
of a casino between 30km and 50km of Belgrade City Hall.
However, the project was delayed several times. As a result, the
government has terminated the concession.
88
Grand Casino Beograd, in cooperation with the city of Belgrade

and the local authority of New Belgrade, is launching an
educational programme for the prevention of aimed at high
school children. The programme will be organised during
Q4 2013 in high schools to inform young people about issues
of problem gambling, its causes, symptoms and treatment.
The educational workshop is based on two segments, both
presentation and theatre play, specifically the experiences and
confession of a problematic pathological gambler, accompanied
by educational and promotional material developed by field
experts.
Grand Casino Beograd also respects the environment by

practising controlled waste storage and the recycling of used
cooking oil, glass, paper-cardboard and toner cartridges.
The Grand Casino Beograd is currently one of two licensed

casinos in Serbia, with 238 electronic gaming positions and 35
table games. Grand Casino Beograd formerly held an exclusive
contract for operational exclusivity within 30km of central
Belgrade until 2015.
The act stipulates that a corporate entity will need to be based

in Serbia to be eligible for a licence, have capital stock of 1m
and have a minimum deposit/bank guarantee of 300,000 in a
Serbian bank for each casino.
Grand Casino Beograd supported gambling research that

showed that 3.6 percent of the adult population of the capital
are gambling addicts, while another 2.5 percent belong in a
high-risk group.
In keeping with good citizenship practices, Grand Casino

Beograd has also minimised its energy consumption
requirements. Through the use of server virtualisation
technology, power consumption needed to keep servers and IT
infrastructure running, and the electricity needed to maintain the
temperature of the data centre, has been reduced by 50 percent.
The Republic of Serbias Ministry of Finance and Economy

oversees the countrys gambling sector and determines whether
a gaming activity should be designated as a game of chance.
The Tax Administration assists with the supervision of games of
chance.
The 2011 Act on Games of Chance, which is set to supersede the

2004 Act, does not contain any limitation on licence numbers.
Early results from the helpline have indicated that the group most
at risk from problem gambling tend to be young adults aged
between 20 and 30 years, usually with an inadequate awareness
of the disorder. Frequently the parents and families of addicts call
the helpline much more often than the addicts themselves.
The casino also sponsored the Radnicki basketball club and

cooperated in the hosting of White Sensation, the worlds
biggest dance event.
In Serbia the organisation of games of chance has to be socially
responsible and organised in a manner that ensures the
protection of minors, and the prevention of addiction for players.
Smoking Ban
Taxation
The Law on the Protection from the Exposure from Tobacco

Smoke entered into force on May 10, 2010 but smoking in all parts
of casinos is allowed. Operators have to ensure that players have
registered themselves before entering the casino.
For house-banked games, the taxable rate is set at 25 percent of

GGR, while for non-house banked games such as poker the tax
rate is 3 percent of GGR.
Gambling operators are required to comply with all applicable

laws governing the protection of personal data regarding the
storage and sharing of player information.
The video recording must be stored for a period of at least ten

days and longer at the request of the administration. The data
may only be shared in specific cases sanctioned by law.
Responsible Gambling Project
In 2010, Grand Casino Beograd signed a Responsible Gambling
Protocol with the Belgrade City Assembly, establishing its role as
a socially responsible organisation addressing issues of problem
gambling. As a result of the protocol, a free telephone helpline
has been set up offering counselling to persons at an early stage
of the disorder.

Although slot hall operators are required to have a minimum of
100 slot machines, holding a casino licence removes any minimum
machine number requirements.
Serbias new regulatory structure has been relatively successful
in diverting gambling funds to the regulated sphere, but
delays in the issuance of secondary legislation has meant the
connection of slot machines to a national central server system
has not yet taken place.
89
2011 figures have put the number of legal slot machines

operating in Serbia at about 17,500, while estimates suggest that
the black market is approximately 30-40 percent the size of the
legal slot machine industry.
Remote Gambling
Online gambling remains the exclusive right of the countrys
state lottery, Dravna Lutrija Srbije, but non-Serbian online
gambling companies have continued to target the country,
particularly the online sports wagering sector.
The Serbian parliament approved the new Act on Games of
Chance that entered into force on December 2, 2011, which seeks
to regulate the online gambling market.
The new act sought to encourage investment by dismantling the
state lotterys online monopoly, prohibiting participation in games
of chance organised abroad, while potentially defending newlylicensed online operators with the possibility of internet service
provider (ISP) blocking.
Accordingly, the Games of Chance Administration drafted a
blacklist of illegal online operators and sent it to ISPs requiring
them to block these websites in mid-February 2012. Among the
blacklisted operators are Bwin, Betfair, William Hill, Skybet, 888
poker and Bet-at-Home. However, the act has also retained
90
provisions that mean the regulated Serbian market will only be

accessible to operators which are willing to set up a company in
Serbia.
Under the new regime, the taxation rate of online betting is
slated to be 15 percent; other types of online games will be
taxed at a rate of 5 percent of GGR. The minimum amount of the
payable tax will be 7,500 per month, and an additional 2,500
per month for the approval.
SLOVAKIA
Slovakias eight casinos saw their revenues grow by

nearly 12 percent in 2012 to 19m, reinforcing a smaller 5
percent rebound registered in 2011.
Fewer gamblers spent more as table game revenues rose
by 10 percent and slots win added 16.7 percent, even as
the number of customer visits fell to 240,000.
Recent tax hikes, particularly on slot machines, have not
succeeded in greatly adding to government revenues
from the gambling sector. Total revenues in 2012 were
119.8m compared with 123m in 2010.
Online gaming is currently not permitted for land-based
casino operators and lottery operator Tipos, whose
only shareholder is the Ministry of Finance, has a legal
monopoly over the remote gambling market.
In 2011 Slovakias Ministry of Finance jettisoned plans to
block foreign online gambling websites in the country
after the move sparked fierce criticism from, among
others, internet service providers anxious to avoid
additional liabilities.
Olympic Casino ilina

Casino Pieany
Olympic Casino Koice
Olympic Casino Trnava
Casino Nitra
Olympic Casino Carlton Bratislava
Regency Casinos Olympic Casino Eurovea Gallery
Bratislava
Olympic Casino Trnava

Olympic Casino ilina
Olympic Casino Koice
Olympic Casino Eurovea Gallery Bratislava
Olympic Casino Carlton Bratislava
Casino Nitra
Casino Pieany
Regency Casinos Bratislava
91

Market Data
Population
Currency
Euro (adopted in 2009)
GNI (Gross National

Income)
US$17, 180 in 2012 (World Bank Data)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
A+ with stable outlook from May 2013, Fitch

Ratings
The Slovak Casino Market

Economic and Political Situation
The global economic downturn has hit the Slovakian economy hard,
although the country rebounded faster than some of its neighbours
following its adoption of the euro as its currency in 2009.
Regulatory oversight of the gambling industry is provided by the

countrys Ministry of Finance which is the only body authorised
to award gaming licences.
The Tax Directorate maintains and operates a tax information
system regarding games of chance, and a keeps a central
register of gambling operators.
The Tax Office is instructed to oversee compliance with the act,
regulations and licence conditions. The Tax Office manages the
levies, which are administered into the state budget, and is also
the second tier body of appeal for municipalities for matters
relating to the licensing of gambling machine operators.
The main legal instrument which governs the gambling sector
in Slovakia is the Act No. 171 on Gambling Games and on
Amendment. Additional amendments to the Gambling Act were
approved in mid-July 2011 and in 2012.
Each individual casino licence issued by the Ministry of Finance is
for a maximum of ten years.
92
Card room venues have a minimum age of 18.
Amendments to the gambling act that came into effect from

January 1, 2013 empower municipalities to ban gambling
activities taking place on their territory provided a petition is
signed by at least 30 percent of the municipalitys population
over the age of 18.
Taxation
Betting games in a casino are taxed at a rate of 29 percent of
the financial guarantee (GGR) provided by each casino, of which
26 percent goes to the state budget and 3 percent goes to the
municipality in which the casino is located.
In December 2012 the governments plan to increase taxation
income for the state saw the tax rate applying to betting, with
the exception of horseracing, increase from 5.5 percent to 6
percent.
Gambling machines saw a tax increase from 1,900 to 2,100
per machine per annum, while the tax rate applying to
machines operated directly by players rose from 3,600 to
3,900 and the taxation rate of machines operated remotely by
telecommunication equipment increased from 3,900 to 4,200
per machine per annum.
Share capital of 1,659,600 is also required.

Olympic Casinos currently sponsors sport clubs, including youth
hockey clubs and canoe clubs. The group also donated to the
Drop of Hope Foundation that helps children with leukaemia.
More recently the outcome of elections in March 2012 saw the

left-wing party SMER Social Democracy return to power, with
Robert Fico again as its head.
Regulator
Tables are taxed at 200 per calendar month or 1,500 per

calendar year.
Each casino must post a minimum financial guarantee of

500,000 and tax is calculated on the basis of the guarantee.
Still, the climate with regard to gambling has not warmed

significantly. A centre-right coalition government elected in 2010
sought to reverse earlier changes that liberalised the countrys
gambling landscape, and effectively did away with any plans to
push forward a politically controversial mega-casino in Bratislava.
Further tax hikes were introduced in December 2012 and came

into effect on January 1, 2013. On the same day, amendments,
which enable municipalities to ban gambling on their territory,
were introduced.
casino premises, came into effect. Card games outside casinos

have gained increasing popularity both in casinos and in
card clubs, and have accounted for much of the new licence
issuance in Slovakia. As of July 2013, about 108 general licences,
predominantly for card games outside casinos and raffles, had
been awarded.
Slovakias Licensed Casino Market

Olympic Entertainment operates two casinos in Bratislava and
three further casino properties in Trnava, ilina and Koice.
Olympic Entertainment had 216 slot machines and 43 gaming
tables in operation in Slovakia at the end of 2012.
In 2012 Slovakias national lottery operator Tipos controversially
sold off its 51 percent majority stake in Casinos Slovakia to
the private firm and minority shareholder Merk Reality for just
150,000.
Merk Reality, which already had a 48 percent share in Casinos
Slovakia, is run by the daughter of prominent MP and longserving member of Prime Minister Robert Ficos SMER-SD party
Dusan Munko.
Casinos Slovakia opened its first casino in Slovakia in 1991 and
currently manages active casino venues in Nitra and Pieany.
Regency Casinos International also manages one casino in
Bratislava.
Poker
In January 2010 a legislative amendment to the gambling act
regulating card games, such as poker, played outside licensed
Gambling operators, including Olympic Casinos, also support a

free telephone helpline that has been operated since February
2013, by the Centre for the Treatment of Drug Addictions
(CPLDZ), based in the capital Bratislava.
Casino operators must display a telephone number for a medical
institution dealing with the prevention and treatment of problem
gambling published on the ministrys website on each gaming
device.
National legislation requires that gamblers must be at least 18

years of age and gambling establishments must display signs
that only players who are over the age of 18 can participate in a
gambling activity.
According to the Ministry of Finances 2012 annual report, there

were 11,765 gaming machines in Slovakia in 2012, a sharp drop
from the 17,373 gaming machines recorded in 2010.
The advertising of jackpots or prizes outside a casino property

or the display of advertising that can be seen from outside is
forbidden.
Operators are required to take all necessary measures to
prevent anyone under the age of 18 taking part in gambling and,
as such, can request proof of identification.
Opening hours and self-exclusion measures are not legislated.
For gaming machines, the maximum deposit amounts are set at
SKK1,000 (10) per position. The act sets out no other limits on
wagers.
The gaming machine market consists of a number of small

domestic companies such as Slov-matic, Program spol and Vix.
However, the tally of gaming machine numbers does not include

video lottery terminals (VLTs), which have proved to be a fastgrowing segment of the domestic market.
VLTs in Slovakia
Number of VLTs
2010

7,383
2011
2012
GGR (m)
145.6m
9,360
193.4m
10,771
221m
93
SLOVENIA
Remote Gambling
Online gaming is currently not permitted for land-based casino
operators and lottery operator Tipos, whose only shareholder is
the Ministry of Finance, has a legal monopoly over the remote
gambling market.
Given the diversity of views within the European Union,
as well as a wide range of dissenting opinions, we
propose to stop the legislative process, said Ministry of
Finance spokesman Martin Jaros.
Private operators in possession of a domestic licence are allowed
to offer online sports betting but only those activities that do not
qualify as gambling games operated by means of the internet.
Foreign online operators without a domestic licence are
prohibited from offering their services in Slovakia, but in 2011
Slovakias Ministry of Finance jettisoned plans to block online
gambling websites in the country after the move sparked fierce
criticism from, among others, internet service providers (ISPs)
anxious to avoid additional liabilities.
Proposals that would have amended Slovakian gambling
legislation to force ISPs and banks to block unlicensed online
operators were widely viewed as taking a step closer to state
censorship of the internet.
The proposals called for a blacklist of websites to be maintained

by the central tax office in Bratislava and updated twice monthly,
in an unprecedented effort by the Slovak government to crack
down on illegal online gambling.
However, following fierce criticism from the chief justice minister,
the banking and ISP sectors and the government requested advice
from the European Commission, which backed the concerns
of the Slovak justice minister, Lucia itansk, who warned the
amendment introduces elements of censorship and may result
in unjustified criminalisation of third-party service providers.
For Tipos, online gambling is currently taxed at 27 percent of
gross gaming revenue.
The taxation rate for betting is 5.5 percent of the financial
guarantee stipulated for betting operations.
Slovenias nine casinos saw their revenues shrink by more

than 10 percent in 2012 to 153m, down from 171m in the
same period a year before.
Table games fared worse than slots, with revenues from
house-banked games contracting by 13.1 percent. Slots,
by contrast, shed 8.2 percent of their previous years total
win.
A new draft gaming bill published in September 2013
proposes the removal of current restrictions on casino
ownership structures; however, larger business shares in
gambling operators would still be subject to approval by
the regulator.
The Slovenian online gambling market is ring-fenced and
only existing casino and lottery licensees are eligible
to apply for an online gambling licence. That restriction
would not change under the new draft gambling bill put
forward in September 2013.
The Office for Gaming Supervision, a branch of the
Slovenian Ministry of Finance, had been responsible for
regulating gaming activities, but the office was closed
due to budget cuts at the end of 2012. Its responsibilities
and tasks are now shared by the Tax Administration and
the Ministry of Finance.
Employment at Slovenias casinos, which had stood as
high as 1,700 jobs in 2010, dipped to 1,305 in 2012 and
contributions to gaming tax fell to 45m.
94
Casino Korona
Casino Mond
Casino Bled
Casino Aurora
Casino Fontana
Casino Perla
Casino Park
Casino Lipica
Casino Portoro
There are nine casinos in Slovenia.

Casino Name
Casino Operator
Casino Portoro
Casino Portoro
Casino Lipica
Casino Portoro
Casino Perla
Hit d.d.
Casino Park
Hit d.d.
Casino Korona
Hit d.d.
Casino Fontana
Hit d.d.
Casino Mond
Hit d.d.
Casino Bled
Casino Bled
Casino Aurora
Casino Kobarid d.d.
95

Market Data
Population
2m in 2011 (World Bank Data)
Currency
Euro
GNI (Gross National

Income)

People
Mobile Phone
Subscribers Per 100
People
A proportion of the revenues from each concession, between 5

and 20 percent of GGR, are put toward local tourist infrastructure
development. There is close collaboration between the casinos
and their local communities in terms of assistance with local
community events, sponsorship and donations.
Doing Business
Ranking

Bank)
Credit Rating
BBB+ with a negative outlook from Fitch

Ratings, May 2013
The Slovenian Casino Market

Economic Situation
The Republic of Slovenia converted its national currency to the
euro on January 1, 2007, shortly before the economic crisis of
2008 began to make its impact felt across the European gaming
industry.
A new draft gambling law published in September 2013

proposes a liberalisation of casino ownership structures;
however, the legislative timetable for the new bill is unclear and
the draft will likely be subject to numerous amendments.
Slovenias Licensed Casino Market
In the wake of budget cuts from January 1, 2013, the Office for
Gaming Supervision was terminated and its responsibilities
were transferred to the Tax Administration and to the Ministry of
Finance.
Hit (Hotel, Igralnice, Turizem, which translates to Hotels, Casinos

and Tourism) owns six of the countrys nine casinos. Hit is a
publicly listed company, with government bodies owning 60
percent of its shares. Of these, 20 percent are owned by the
municipalities, 20 percent by a government-owned entity and 20
percent by public employee pension funds.
A 2011 report by the Office for Gaming Supervision indicated that

by 2011 the number of casinos had dropped to nine from 12 in
2008. In the same period the number of gaming tables dropped
from 282 to 260 and the number of slot machines from 4,236 to
3,957.
Slovenias other two casino operators are the Portoroz

Company, which operates two properties, one in the seaside
town of Portoroz, and one in the town of Lipica, and the Casino
Bled company which operates Casino Bled in the tourist
destination of Bled.
Responsibilities in gambling regulation are now shared by the

Tax Administration and the Ministry of Finance of the Republic of
Slovenia.
Slovenia is among the countries that had to answer questions
from the European Commission, which were sent as part of the
commissions action plan, regarding the EU law compliance of
their gambling regulations.

No one under the age of 18 years may play casino games or
participate in online gambling in Slovenia. Casinos and gaming
halls share the same legislation regarding responsible gambling,
player self-exclusion and age limits.
Self-Exclusion
The Slovenian Gaming Act provides that players can submit a written
statement that they would like to be excluded from special games of
chance in a casino or gaming hall as well as online gambling.
The self-exclusion may last for a maximum of three years but a
minimum of six months, and must be signed personally by the
player concerned.
The self-exclusion will subsequently apply throughout the
territory of Slovenia, and the supervisory authority is responsible
for maintaining a central register of excluded players.
Smoking Ban
A smoking ban in public places came into force on August 5,
2007 in Slovenia. The exceptions to the ban, however, include
special indoor smoking cabins (designated solely for smoking),
which are subject to strict technical requirements.

Gaming halls in Slovenia were introduced with the 2001
amendment to the Gaming Act.
According to 2011 figures published by the Office for Gaming
Supervision, the number of slot machines dropped from 4,236
to 3,957 during the period between 2008 and 2011.
The Gaming Act does not limit the number of concessions awarded
to one company and, in practice, one company usually has more
than one concession for conducting casino gaming in casinos or
concessions for games in gaming halls. No more than 45 gaming
hall licences may be awarded in total under current rules.
A gaming hall must have a minimum of 50 and a maximum of 200
slot machines and should be located in an area with the infrastructure
for tourism. There is no restriction on the number of slots in a casino.
Remote Gambling
The Slovenian online gambling market is ring-fenced and only
existing casino and lottery licensees are eligible to apply for
an online gambling licence to offer gambling products that are
already granted to them under their respective concession.
That restriction does not change under the new draft gambling
bill put forward in September 2013, although the new bill follows
recommendations from an EU Resolution from September 2013
urging stricter control over non-licensed online providers.
The maximum number of online casino licences available is
11 and two online lottery licences are allocated. Non-licensed
operators will not be able to legally operate in Slovenia or take
play from Slovenian players under the new draft law.
Under the existing Gaming Act, the Slovenian government

can award a maximum of 15 concessions for casinos and 45
concessions for gaming halls. Under current laws companies are
limited to having a 49 percent stake in any casino, while the rest
must be retained in government ownership.
The Office for Gaming Supervision (in operation until the end of 2012)
noted that concession holders are already experienced in offering
each type of gambling through their land-based operations and are
the most appropriate licensees to offer those products online.
Slovenias casino operators provide warnings about risk of

gaming for each gambler in casinos, both on the entrance ticket
and in brochures (pamphlets).
In 2007, Loterija Slovenije started to develop a new sales platform

for all its games on the internet. The operator now offers its online
products on a separate website under www.eloterija.si.
In 2010 Slovenias government put forward a draft strategy

for the gambling sector that would have allowed for private
developers to own a majority share of each casino project.
Taxation
portna Loterija offers online sports betting through its website

www.e-stave.com (e-stave translates as e-betting).
Following on from the strategy discussions a new draft gambling

law was published in September 2013. The new law calls for the
liberalisation of ownership structures, eliminating percentage
ownership quotas, although substantial shares in gambling
operators would still be subject to approval by the regulator.
Potentially the draft measures, if approved, could open the door
for a return of a mega casino development in Slovenia by adding
economic incentives and tax reductions for new projects.
Regulator
96
Concessions are granted for a period of ten years but may be

extended several times for a period of five years.
Under the Law on Tax on Gambling, GGR in casinos and gaming

halls are subject to an across-the-board 18 percent tax. In
addition, concession fees apply.
HIT Casinos offers online gambling, including card games, poker,

roulette and online slots, on its website www.hitcasinos.si.
Online operators are obliged to ensure that the player can set a
maximum limit for each game or game session, or a maximum
spending limit within a specified period of time.
Currently the Slovenian government grants gaming concessions

on the basis of a number of different circumstances, including:

Impact of gaming on social, cultural and natural

environment.
Development of gaming activity.
The extent of gaming in a certain area.
Gaming experiences of the applicant.
97
SPAIN
Spains 43 casinos have seen their revenues shrink in the

last six years as flat or declining economic growth and
high unemployment has crushed consumer spending.
That downward trend has been accelerated by Spains
smoking ban and online competition.
The future of Spains land-based casino sector is
dominated by the prospects of two multi-billion euro
casino resorts in Madrid and Barcelona. Las Vegas
Sands has plans in Madrid for as many as 16 casinos
as the centrepiece to a European version of Las Vegas,
dubbed EuroVegas, while Spanish property tycoon
Enrique Banuelos has partnered with Macau casino
operator Melco International to build a rival resort called
Barcelona World.
A carve-out from Spains smoking ban has become a
sticking point in Las Vegas Sands negotiations with
national and regional officials. Casinos, bingo halls and
slot arcades have all seen heavy revenue declines since
the ban came into effect in 2011.
There are 43 licensed casinos in Spain.
The state-owned national lottery (LAE) and slot machines

found in bars, arcades and gaming halls are by far the
most popular gambling products in Spain. Between the
two they accounted for 75 percent of the total markets
8.67bn gross gaming revenue in 2012.
Online gambling was licensed and formally taxed for the
first time in June 2012. Fifty-four operators were awarded
almost 300 product licences, but already a second-hand
market has opened up in unwanted and barely-used
licences as revenues stagnate.
No Spanish casino is in the top five online gambling
operators as the regulated market has quickly been
taken over by internet-only operators, PokerStars,
888 and bet365, which were accepting Spanish
gamblers before licences were officially issued.
99
Market Data
Population
Currency
Euro
GNI (Gross National

Income)
$30,110 (World Bank Atlas Method 2012)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking
42 (2012) and 44 (2013) (Doing Business,

World Bank)
Credit Rating
BBB (Fitch 2012)
The Spanish Casino Market
Smoking Ban
Regulator
Smoking was banned in most enclosed public spaces, including

casinos, bingos and gaming parlours, from January 2011, and has
been blamed in part for casinos ongoing decline.
Casino operations in Spain are regulated at a regional level.

Each autonomous community designates its own gambling
regulator, which, in most cases, is associated with local tax or
administrative authorities.
All casino concessions are awarded through public tenders and
their duration varies from one region to another. The average
licence is granted for approximately ten years, although in
certain regions it can last for 30 years.
At a national level, the Direccin General de Ordenacin del
Juego (DGoJ) is responsible for regulating online gambling. The
DGoJ, which is led by Carlos Hernndez Rivera, is part of the
Ministry of Finance and was empowered by the 2011 Gambling
Act.
Spains Licensed Casino Market
Spains casino sector has been badly hit by a potent mix of
factors including the countrys economic woes, the smoking ban
and online competition.
The 43 casinos open at the end of 2012 made total gross gaming
revenue (GGR) of 305m, a fall of 9.8 percent compared to the
previous year.
The sector has declined every year since 2007 when revenues
were almost double the 2012 level at 554m.
The bulk of the 2012 decline came in table revenues, which
decreased 13.2 percent year-on-year to 171m. Casinos slot
revenues fell only 1.9 percent to 105m. At the same time, the
number of visitors declined by 5.6 percent to 4.13m.
Casino employment remained flat at approximately 6,000 in
2012, partly due to tax incentives in certain regions.
As of October 2013, French casino firm Groupe Partouche was
on the verge of selling its casino in San Roque, Andalucia. The
casino, located near Cadiz, first opened in 1999, but was forced
to shut its doors in 2010.
100
A register of non-authorised persons is managed by the regional

governments that casinos report to, and those players included
in the register are not allowed to enter casinos.
The Spanish Casino Association adopted its own code of
conduct on these areas in 2007 and that was implemented by
all its members. Many operators also have player protection
programmes that include problem gambling leaflets, hotlines
and information inside the casino.
In October 2012, the Spanish Association of Private Psychiatry
estimated that 5 percent of the Spanish population was affected
by some form of gambling problem.
Spains EuroVegas
LVS president Mike Leven said in February 2013 that
the company hoped to open the first phase of its 12- to
16-casino project by 2017 or early 2018.
We are proposing to build the European version of the
Las Vegas Strip not the Las Vegas Strip in Europe, LVS
president Mike Leven said in February 2013.
This is going to be a pristine experience, and I think its
going to be the best in the world.
Madrids regional parliament approved a bill at the end of
2012 to enable the construction of a so-called integrated
development centre (CID). The new legislation relaxed
many of the gambling laws in place for other Spanish
gambling operators as it enabled 24-hour opening and
lifted a long-standing ban on offering players credit. CID
projects would also be subject to a public tender.
Real estate billionaire Enrique Banuelos claims backing
from Asian casino operator Melco International, as well
as hotel and shopping mall partners to build the rival
Barcelona World.
Player Protection and Problem Gambling
Spanish casinos check before a player enters whether they are
underage or an excluded problem gambler. It is forbidden for
people below 18 years of age to enter casinos.
Asturias, Castilla y Leon, La Rioja, and Murcia have also

introduced a discounted tax rate for casinos that maintain a
minimum number of employees, as the regional governments
look to safeguard jobs. Tax in Asturias and Murcia starts as low
as 15 percent for those casinos.
Spain makes a legal distinction between slot machines, split
into categories A, B and C. Category B are amusement with prize
(AWP) machines and are by far the most popular.
In 2012, GGR from category B machines found in bars, arcades
and bingo halls was 2.75bn in 2012, 32 percent of the total
revenue raised by Spains gambling market (8.67bn).
Video lottery terminals are not currently regulated in Spain, and
slot machine operators have lobbied for reforms to the landbased gaming market before online slots are liberalised.
However, Las Vegas Sands (LVS) chairman Sheldon Adelson is

pushing for EuroVegas to be given an exemption from the 2010
smoking law, and indicated in Summer 2013 that it is a sticking
point in negotiations for his casino complex on the outskirts of
Madrid.
Spains existing casinos are watching negotiations closely and
will push for any concessions to apply to them too.
Casinos also have to pay taxes to municipalities, which are

charged on the existing number of tables and slots in a casino.
Online casino games are taxed at 25 percent of GGR, lower than
the rate charged on most land-based casinos.
The real industry is not online, its on the street, said

Jaime Estalella, chief operating officer of Spanish gaming
firm Codere.

Licensed remote gambling operators are required to establish
systems and mechanisms which facilitate player identification.
Online players must be aged 18 or over.
The identification of players can be done through a unique
register which must record at least: the players identification
details; and confirmation that he or she has not been banned or
excluded from accessing gambling services.
Social Responsibility, Contributions to Good Causes
Unclaimed chips or prizes are given to the municipality where the
casino is located. Casino operators have their own contribution
agreements with institutions and charitable groups.
Im not saying that by approving online slots we are

going to destroy the other market, but we need to
improve the offline level, said Estalella.
Some Spanish regions have recently increased the maximum
stakes and prizes on Class B slot machines to make them more
competitive.
Spains Chamber of Deputies also passed the Law on Market
Unity, which seeks to remove duplicate regulations across
Spanish regions. In the gambling sector, slot machine
manufacturers stand to gain most from more standardisation
between regions, which have small but significant variations
in technical standards down to the size of the machines
joysticks.
Taxation
Each Spanish region is responsible for its own tax on casino
gambling. Tax is charged on the income from tables and slots,
and is calculated on a sliding scale whereby casinos move into a
higher tax band if they surpass certain revenue levels.
The autonomous community of Madrid charges 22 percent
tax if annual GGR is below 2m and 45 percent if above 5m.
Madrids regional parliament passed a law at the end of 2012
which will lower the tax rate to 10 percent for all casinos when
the regions integrated resort (CID) opens.
Catalonia also plans to reduce tax to 10 percent to help
Barcelona World compete with the Madrid resort. The new rate
would start when Barcelona World opens and would benefit all
casinos open in Catalonia.
101
Remote Gambling
In 2011, a new Gambling Act was passed by Spains parliament
in just three months under emergency proceedings as the
then-Socialist government looked to raise extra funds amid a
mounting sovereign debt crisis.
The new law sought to tax and license online gambling for the
first time, bringing to an end years of legal uncertainty.
The regulated online gambling market launched in June
2012 when the DGoJ issued online licences to 54 operators,
including 21 companies that specialise in online casino games.
The licensing procedure was open to all companies, with no
requirement to have a land-based licence or a server located in
Spain.
In the first 12 months since the markets launch in June 2012,
online gambling gross gaming revenue was around 218m,
according to the DGoJ. However, the regulator has conceded
that revenues have since stagnated in 2013.
Companies have blamed the ban on online slots, betting limits
and a tax rate of 25 percent for the underwhelming start to
Spains regulated market.
Roulette, black jack, punto banco and poker were all permitted,
but not online slot games. The DGoJ announced in April 2013
that it would license online slots once a ministerial order goes
through public consultation and is reviewed by the Ministry of
Finance.
The future of gaming will be in the merger between landbased and online, said Heliodoro Giner, secretary general
of the Spanish Casino Association.
Official market share numbers for the first 12 months showed
that offshore operators control most of the regulated online
market. 888, Bwin and Gamesys, all licensed in Gibraltar, hold
more than half of the combined casino and bingo market.
Several regions also have online gambling regulatory
frameworks in place. Madrid, Castilla y Leon and the Basque
have approved legislation regulating remote gambling services.
In September 2013, Catalonia also sent draft legislation to the
European Commission to regulate online betting.
SWEDEN
State-owned Svenska Spel is the only operator authorised

to operate casinos in Sweden and it does so under the
Casino Cosmopol brand. There are currently four casinos
in the country located in Stockholm, Gothenburg, Malm
and Sundsvall.
Swedens regulatory model is a monopoly system where
two state-controlled companies, Svenska Spel and the
Swedish Horse Racing Totalisator Board (ATG), are the
only licensed operators to offer gambling in the country,
except for a number of non-profit organisations licensed
to organise lotteries.
Svenska Spel offers sports betting, online poker, lotteries,
land-based VLTs and casinos but does not offer online
casino games.
Online poker has been on a steep decline in the last few
years and quarterly net gaming revenue hit an all-time
low in the second quarter of 2013 at SEK35.6m (4.1m).
Unlicensed operators have established a big presence
in the Swedish online market, with Svenska Spel
estimated to have a market share online of just 24
percent throughout 2012 and the first half of 2013.
Casino Cosmopol Sundsvall
Casino Cosmopol Stockholm

Casino Cosmopol Gothenburg
Casino Cosmopol Malmo
Casino Cosmopol Gothenburg

Casino Cosmopol Malmo
Casino Cosmopol Stockholm
Casino Cosmopol Sundsvall
Swedens monopoly framework has been subject to

scrutiny by the European Commission and although it
has reassured the commission that it is looking into its
regulatory regime, the Swedish government announced
in 2013 that it will not make any changes for at least two
years while examining other member states progress.
Svenska Spels VLT game Vegas is the most popular game
in the country, with net gaming revenue amounting to
SEK2bn (230m) in 2012.
102
103
Market Data
Population
Currency
Swedish krona
GNI (Gross National

Income)
US$56.210 (World Bank 2012)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
AAA (Fitch 2013)
The Swedish Casino Market
Regulator
Net gaming revenue for Casino Cosmopol has remained

relatively steady in the last few years after reaching its peak in
2008 at SEK1.2bn (140m).
Only the Swedish government can grant licences to operate a

land-based casino in Sweden.
Svenska Spel generated net gaming revenues of SEK9.8bn

(5.1bn) in 2012, of which SEK1.2bn (127m) came from Casino
Cosmopol and SEK2bn (231m) from Vegas machines.
The number of visitors to the four casinos declined somewhat in
2012 amounting to 1.2m visitors.
At the beginning of the year, Casino Cosmopols chief executive,
Per Jaldung, said that unlicensed online casinos are now making
more money than Swedens four land-based casinos and that
the competition from online casinos is proving tough.
Its like bringing a knife to a gunfight. You have to make
sure youre really good. Per Jaldung, Casino Cosmopol
chief executive.
Casino Cosmopol employs 934 people on a full-time basis in its
four casinos, and around 1,400 staff in total.
According to the Swedish Gaming Board, Swedes spent an
average of 296 per resident on gambling in 2012.
Live poker tournaments are held at Casino Cosmopol daily with
some major events throughout the year.
Casino Cosmopol has also launched Lets Play where guests

can get an introduction to the most common games in a quieter
environment and with lower stakes.
During the first six months of 2013 Casino Cosmopol made 140
reports to the Swedish Financial Police with regard to suspicious
money laundering activities. The number has remained stable in
the last few years.
The Casino Act 1999 includes the prohibition of granting
of credits, prohibition of employees participating in casino
gaming, socially responsible marketing that is not aggressive,
responsibility to actively work against problematic gambling and
maximum bet size and minimum re-pay percentage.
A smoking ban is in place in Sweden.
Now the online casinos have really heavy marketing and

are basically taking care of all the growth. They do not
have a licence to be in Sweden but they are still estimated
to be making more money than land-based casinos, Per
Jaldung, Casino Cosmopol chief executive.
The profit goes to national and local sports clubs and childrens
and young peoples sport.
Last year, Svenska Spel contributed SEK5.1bn (580m) to the
state.
The age limit for casinos is 20 and registration is needed to

enter a casino. The Swedish government places considerable
emphasis on addiction prevention and player protection.
Casino Cosmopol holds mandatory training programmes in
responsible gaming for its employees. The staff also hold
dialogues with guests aged 20 to 24 who visit the casino more
than five times a week over a three-month period as they
represent a high risk group.
Svenska Spel is exempt from tax but state-controlled ATG,

which is owned by Swedens horse racing organisations, is not
exempt. Any profit is distributed to the government and the
horse industry.
Svenska Spels Vegas machines are the only gaming machines
authorised to be placed outside casinos in Sweden. There are
around 6,700 Vegas machines in Sweden located in bars and
restaurants with a permit to serve alcohol and in bingo halls
around the country.
The maximum stake is SEK5 (0.5) and the maximum jackpot is
SEK500 (58).
Svenska Spel does not advertise its Vegas brand as it regards
this to be a more risky game than lotteries, scratch cards and
sports betting.
Vegas is the most popular game in Sweden, with net gaming
revenue amounting to SEK2bn (231m) in 2012.
Remote Gambling
Both Svenska Spel and ATG offer their games online, but Casino
Cosmopol is not licensed to go online with its games. Svenska
Spel said 25 percent of its net gaming revenues came from
online in 2012.

Svenska Spel, and Casino Cosmopol, is exempt from tax,
being a state-owned company, but all profit from the casinos is
transferred to the state and goes to good causes.
Taxation
Svenska Spel has received criticism that the terminals increase

the number of problem gamblers in the country and launched
an investigation into the machines to see if improvements could
be made to make it easier for players to control their gambling.
Svenska Spel is now implementing carded play to their VLTs to
allow players to set their own limits on time and spending.
In 1999, the Swedish government granted Svenska Spel a licence

to build four casinos. The first one was opened in Sundsvall in
July 2001 and the other three were completed by March 2003.
Player Protection
The marketing of the casino games is restricted and TV or radio

advertising is forbidden.
However, the Swedish Gaming Authority (Lotteriinspektionen)

regulates and supervises the entire gambling market in Sweden
and makes sure that it is safe, legal and reliable.
In 2012, Svenska Spel launched Svea, a sponsorship programme

for amateur and youth sports where SEK50m (580,000) is
divided between clubs chosen by customers.
104
Guests can sign voluntary agreements about limiting casino

visits or completely exclude themselves for at least two months.

The age limit for all forms of gambling apart from land-based
casinos is 18.
Svenska Spel does not currently offer online casino games but
observers suggest the monopolist should be allowed to offer
casino online as it is the fastest growing game on the market,
currently only being offered by unlicensed operators.
To open up an account with Svenska Spel, customers have to:

Be at least 18 years of age

Have a Swedish bank account
Have a permanent address in Sweden
Have a Swedish social security number
Svenska Spel requires its customers to set a weekly limit on

how much money they are willing to spend. Lowering the limit
can be done straightaway, but if the customer wants to raise the
maximum spend they must wait a week before the change gets
adopted.
Playscan is a subsidiary of Svenska Spel and it offers tools for
the customer to control and analyse their gambling habits and
offers information on how to deal with problem gambling.
Svenska Spels player card is not compulsory but widely used
and customers can exclude themselves by blocking the card for
as long as the customer wants.
105
SWITZERLAND
Svenska Spel launched online poker in 2006 after the
government became concerned that a large number of
Swedish players turned to unlicensed websites during the
poker boom. Svenska Spel now offers several online poker
tournaments throughout the year, including the online Swedish
Championship.
In 2012, online poker net gaming revenue dropped 18 percent on
the year before to SEK175m (17m), down from SEK372m (37m)
in 2008.
Svenska Spel estimates that there are a record number of
unlicensed operators in the Swedish market, about 150, which
accounted for around 14 percent of the entire Swedish gambling
market in 2012.
The Swedish regulator lacks strong enforcement measures to
deal with unlicensed operators.
Swedens Supreme Court last year ruled in favour of media
companies that advertise online gambling operators, judging
that they cannot be sanctioned even though it is still illegal
under Swedish law to promote unlicensed gambling. Unlicensed
gambling operators targeting Sweden now advertise on
billboards and newspapers in the country, as well as Swedish
and foreign-based TV channels.
The government has said it will try to strengthen the Lotteries
Act and the ban on promoting unlicensed operators while
examining whether it will make any changes to the gambling
policy.
106
Lennart Kll, CEO of Svenska Spel, said of the ruling:

The judgment and the development we see with more
advertising for games with higher risk underscores
the importance of an effective system of sanctions for
infringements of the prohibition on promotion.
My view is that we need extensive restrictions for the
entire market on the advertising of gambling. This is partly
to protect the consumer but ultimately also about what
kind of society we want.
Faced with an increase in marketing spend from unlicensed
operators, Svenska Spel has upped its own advertising spend to
be able to compete, spending more than SEK1bn (115m) in 2012.
The total advertising spend in the country exceeded SEK2bn
(231m) in 2012, which was more than Finland, Denmark and
Norway combined.
Switzerlands casinos saw an 8 percent drop in yearon-year revenues in 2012, as they faced additional
Swiss Casinos Schaffhausen
Grand Casino Basel
competition from operations close to the border of
Grand Casino Baden
Grand Casino St Gallen
Switzerland and from internet gambling operators. Weak Casino Barriers Jura
Casino Zurich
economic conditions in neighbouring European countries
Casino Bad Ragaz
Casino Neuenburg Grand Casino Kursaal Bern
also weighed on player spend.
Casino Davos
Casino Barrier Fribourg Grand Casino Lucerne
Casino Interlaken
The decline suffered by casinos in French and GermanCasino Barrier Montreux
Casino St. Moritz
speaking cantons was not as bad as those which relied on
Casino
Crans
Montana
Italian visitors.
Grand Casino Locarno
Casino du Lac Geneva
Casino Lugano
Casino Admiral Mendrisio
The countrys 21 casinos saw total revenue of CHF757m
(612m) in 2012, but not a single operator was able to

maintain revenue at 2011 levels.
Online casino gaming is prohibited but at the same time

no blocking measurements are currently in force against
foreign unlicensed offerings, adding to competition for
land-based casinos.
A draft law creating a new legal framework for gambling
and lifting the current ban on online gambling in
Switzerland is expected by the end of 2013. A consultation
will take place before the bill can be passed by the
parliament.
Swiss law bans the operation of slot machines outside
licensed casinos, although 600 electronic lottery
terminals are operated by Loterie Romande. The illegal
gaming market, both land-based and online, is growing
fast.
Switzerland has now allocated 21 casino

licences, eight have a Class A licence and
13 operate with a Class B licence.
The large Class A casinos are in urban
areas: Zurich, Baden, Basel, Berne, Lugano,
Lucerne, Montreux and St. Gallen.
The Class B casinos are in resort
towns or smaller communities: Bad
Ragaz, Courrendlin, Crans-Montana,
Davos, Granges-Paccot, Interlaken,
Locarno, Mendrisio, Meyrin, Neuenburg,
Schaffhausen, St. Moritz and PfffikonZrichsee.
107
Market Data
Population
online product offers, also means that gaming is more available

at home for many Italian players.
Currency
Swiss franc (CHF)
Regulator
GNI (Gross National

Income)

People
Mobile Phone
Subscribers Per 100
People
Doing Business Ranking

Bank)
Credit Rating
AAA, Standard & Poors, 2011
The Swiss Casino Market

In June 2011, the Swiss government awarded two new casino
licences: one Class A licence to Swiss Casinos for a casino in
Zurich and one Class B licence to FBAM Neuchtel SA to operate
a casino in Neuchtel, making a total of 21 licences in operation.
with a higher proportion of foreign customers saw decreases in

footfall, and overall visitation fell by 3.8 percent between 2011
and 2012.
The Class A and B licences valid today were granted until 2023.
In France, Germany and Italy new opportunities to gamble have

proliferated, so foreign visitors come less often and, as the
economic situation in their own countries is strained, they have
less money to spend when they do.
Swiss law bans the operation of slot machines outside licensed

casinos. Gaming machines are authorised in Class A and Class B
casinos.
In addition the strong Swiss franc has a negative impact since

foreign customers receive fewer Swiss francs for the same
amount of euros than before.
Last year, people were spending less, now were

beginning to see fewer guests too. Luca Antonini, general
manager at Lugano Casino.
Poker
Federal law distinguishes two types of casino games: games of
skill and games of chance. Games of chance can only be offered
in casinos.
On May 20, 2010, the Supreme Court of Switzerland classified
Texas Holdem poker tournaments as games of chance; giving
casinos an effective monopoly on the organisation of poker
tournaments.
The Swiss Casino Federation welcomed the decision of
the Supreme Court, claiming that up to 100 Texas Holdem
tournaments had been taking place each week outside casinos
as a result of the Swiss Gaming Boards prior consideration.
Lugano Casino saw a 21 percent decline in revenue to CHF54m

francs (44m) the biggest fall of any Swiss casino. Around 80
percent of visitors are Italian but numbers are falling.
Meanwhile, at the Admiral Casino in Mendrisio, just five minutes
from the Italian border, gaming revenue fell 12 percent to
CHF64m (52m) last year.
The figures are also reflected in staff numbers, with the number
of employees at the Lugano Casino down 43 percent in 2012
from 2008 and the headcount in neighbouring Mendrisio
shrinking by 25 percent in the same period.
The drop in visitors is partly explained by the stalling Italian
economy, where unemployment is running at 12 percent.
It was a huge parallel business that was expanding, said

Marc Friedrich, the casino associations general secretary.
In casinos we have to control customers entry to the
casino, we have to verify their age and we have measures
in place to guard against gambling addiction but all the
third-party organisers of these poker games do not have
to do these things.
In the meantime there has been a tightening up of enforcement

of the existing laws. In 2012 two casinos paid fines of 1m and
2.5m respectively.
On March 11, 2012, Swiss citizens were called to vote upon a
modification of Article 106 of the Swiss Constitution which
provides the legal basis for organised gambling in Switzerland.
The vote was passed with 87 percent in favour.
The new Article 106 regulates all kinds of games for money:
casinos, lotteries, betting and skill games. Based on this a new
law for games for money is being drafted which will cover all
kinds of games for money including online gambling.
The Federal Department of Justice and Police, together with
representatives of the Swiss cantons, the gaming sector and
addiction experts, are now working to create the new legal
framework.
A draft law is expected by the end of 2013 and a consultation will
take place before a bill can be passed by the parliament.
The council, which constitutes the federal government
of Switzerland, indicated that online gambling should be
conducted according to the same rules and criteria as offline
games. It added that the focus should be on safety and the
protection of minors and problem gamblers.
COMLOT, in its annual report for 2012, said the ongoing
legislative process would also focus on the manipulation of
sports events through betting as an alarming number of cases
were revealed in Switzerland in 2012.
The Swiss government, in February 2013, published some

guidelines for its future gambling legislation, including plans to
abolish winnings taxes on all games and to lift the current ban
on online gambling, with the objective to stop all revenue from
online gambling leaving Switzerland.
No blocking measures are currently in force against foreign
unlicensed offerings.
Advertising illegal gambling is prohibited.
The Swiss Gaming Board is empowered to launch criminal suits
against advertising and marketing activities that promote online
gambling (including hyperlinks on a website) but in practice no
enforcement takes place.
Gaming tax goes mainly to the old age insurance (staatliche
Altersvorsorge).
National legislation requires customers to be at least 18 years
old, a measure enforced by the requirement that all casino
patrons must have an ID card before entering a casino.
Under the Act on games of chance and gambling establishments
(LMJ), all casino operators must produce an annual report
outlining their efforts in fighting problem gambling. Each must
also adopt a Social Awareness Plan describing what will be done
in the future to improve problem gambling resources.
A smoking ban came into effect in Switzerlands casinos in May
2010.
Players must be over 18 years old.
Casinos have a duty to bar players when they know or have to
assume that they are:
Each casino is required to ask regular guests to provide

documents proving their financial situation. If these documents
are not provided or if as a result show that a customer is playing
beyond his or her financial means then the casino must bar that
customer.
The Swiss economy has managed to pull through the European

financial crisis without much harm and with continuing low
unemployment figures.
108
Although between 2010-2012 there was no actual change to the

gaming law several proposals have emerged that will reshape
the market in the near future.
Online casino gambling is currently prohibited in Switzerland

under the 1998 Gaming Law, apart from some games offered by
the duopoly of the two lottery companies Swisslos and Loterie
Romande.
1. Heavily indebted
2. Risking wagers being disproportionate to their income or
wealth.
Economic Situation
Still, visitor numbers and revenues in casinos close to the border
The Swiss Gaming Board is a government agency which has

regulatory oversight over casinos and has a general mandate
to enforce Switzerlands gaming laws. The Swiss Lottery and
Betting Board (COMLOT) regulates lotteries and betting.
Online Gambling
The relaxation of Italian gaming laws, including an expansion of
At any time a customer can chose to self-exclude, and those

that are excluded are barred from all casinos in Switzerland.
They are placed on a list which can be accessed by all casinos in
Switzerland.
109
UNITED KINGDOM
Each time a customer seeks to enter a casino proper
identification is demanded and checked for both age verification
and cross-referenced against the database of those barred from
entering casinos.
Each casino must have a responsible gaming programme
(Sozialkonzept) to prevent visitors from engaging in excessive
gambling.
Casinos must provide patrons with readily accessible
information on the risks of gambling and the help available to
problem gamblers. In addition, all client-facing casino personnel
must be trained each year for two days on how to detect and
approach problem gamblers, and be able to provide information
on available assistance.
Each casino must also disclose the number of exclusions
referred to addiction prevention services during the last year and
how many exclusion orders were issued (or lifted) every year.
Taxation
Casino taxation is regulated as follows:

Casinos (A and B) pay taxes based on their gross gaming

revenues (GGR).
CHF0-10m: 40 percent.
CHF10m-90m: for each additional million francs of GGR
the taxation rate rises by 1 percent.
Over CHF90m taxes are levied at 80 percent.
The Swiss Federal Council is free to change the level of taxation

at any time and set rates between 40 and 80 percent of GGR.
Taxation is now based upon a model which progresses with the
level of revenues.
As the gross gaming revenues of Class A casinos average
CHF70-90m per year, their effective tax rate is more than 50
percent. Class B casinos are also paying more than the base 40
percent rate on CHF10m as they each generate CHF25-30m in
profits per year.
A total of 146 casinos and two licensed card clubs operate

in the UK. Two casino groups operate the majority of
casinos: Genting UK with 44 casinos and Rank Group with
55 casinos.
The UKs casinos saw total revenues of 872m (1.035bn)
in 2012, a 9.4 percent jump on the previous year, as
table games grew their takings by 9.6 percent and slot
revenues swelled by 8.4 percent.
More visitors than ever before came to the UKs casinos in
2012 with a total of 18,240,000 visits, up 4.9 percent on the
year before, and Britains casinos employed 14,323 staff, a
6.6 percent increase on the year before as nearly 900 new
jobs were created.
Londons high-end casinos have continued to outperform
those casinos designated as Other London and
Provinces in terms of growth in table game drop, and
experienced a particular boost from the 2013 Champions
League final that took place in London.
All of the UKs provincial regions are decelerating
in terms of casino growth in drop and win, although
Scotland is the only region which has entered negative
growth territory.
London casinos have outperformed their

regional rivals in terms of table gaming as
spend by foreign gamblers has remained
strong.
Machine Games Duty (MGD) was introduced on February

1, 2013, replacing the former Amusement Machine Licence
Duty (AMLD) with an effective 20 percent taxation rate on
machines in casinos and adult gaming centres (AGCs).
There are now two large casinos, in London and Milton
Keynes, operating with Gambling Act 2005 licences. The
others operate within Gaming Act 1968 limits.
All data: UK Gambling Commission 2013.
110
111

Market Data
Population
Currency
Pound sterling
GNI (Gross National

Income)

People
Mobile Phone
Subscribers Per 100
People
Doing Business
Ranking

Bank)
Credit Rating
Aa1 down from AAA, Moodys, February 2013
The UK Casino Market
The UKs Licensed Casino Market
Regulator
The Gambling Act 2005 introduced a licensing regime for new

large casinos and small casinos while permitting the continued
operation of casinos by the process of applying to convert a 1968
Act licence.
The United Kingdoms gambling regulator is the UK Gambling

Commission.
No changes that affect land-based casinos have occurred since
implementation in 2007 of the Gambling Act 2005.
The Gambling Act 2005 removed the membership requirement
for casinos and bingo halls as well as the 24-hour waiting
period for membership. It introduced a regulatory framework
for remote gambling within the UK and created the Gambling
Commission.
The changes to the UKs gaming market in 2005 were
introduced to regulate new forms of gambling and associated
technological changes. However, the new regulatory system has
been the subject of extensive inquiry and discussion regarding
how successful the Gambling Commission has been in meeting
its licensing objectives.
The Department for Culture, Media and Sport (DCMS) conducted
a consultation in 2011 to assess the impact of the Gambling
Act 2005 and whether it had fulfilled its objectives of player
protection, fraud and money laundering prevention. The DCMS
also looked at why there have been delays in implementing new
2005 Act casinos.
The regional casino proposal has since been scrapped. The UKs
second large casino, the Aspers operated Casino MK, opened
its doors in Milton Keynes in September 2013, joining the Aspers
Westfield Stratford City casino, which opened in December 2011
ahead of the London 2012 Olympics.
The United Kingdoms casinos make voluntary levy payments

to the Responsible Gambling Trust (RGT) or other bodies
involved with the research, education and treatment of problem
gambling.
Age Restriction
Remote Gambling
National legislation makes it an offence for someone who is

under 18 years old to enter a casino.
The online provision of gambling in UK casinos is currently forbidden.
Self-Exclusion
According to Gambling Commission rules about self-exclusion,
licensed operators must have procedures that take all
reasonable steps to refuse service or to otherwise prevent an
individual who has entered a self-exclusion agreement from
participating in gambling.
Gambling Prevalence
The latest British Gambling Prevalence Survey, from 2010, states that:

There are 186 converted 1968 Act licences in the UK. In total 142
licences are operating, of which two are new large 2005 Act
casinos.
Rank Group agreed to buy Gala Coral in May 2012, and the UK
Competition Commission subsequently gave its approval to the
deal subject to four casinos and three inactive licences being
excluded from the deal.
Casino licensing came under scrutiny by the DCMS Select
Committee in its report from July 2012, The Gambling Act 2005:
A bet worth taking?.
As a result of the Gambling Act 2005, any remote gaming

operator based in the European Economic Area (EEA), including
Gibraltar, or a white-listed country, can advertise in the UK
without paying the standard UK gambling taxes, as long as they
do not have any of their remote gambling equipment in Britain.
Further, licence holders should take steps to ensure that the

self-exclusion period is a minimum of six months.
Two casino groups, Genting UK and Rank Group, now hold the
majority of UK casino licences.
gaming into high street betting shops.

The UK government has indicated it would prefer to take no
action on the issue of FOBTs (defined as B2 machines) until the
study into gaming machines by the RGT has been completed.
Additionally, the government has indicated it would like to
raise the maximum stake from 2 to 5 for B1 casino gaming
machines (technically defined as B1 machines).
No small casinos are to date operating.
In relation to casinos, the DCMS Select Committee

recommended scrapping the two-tier system and recommended
that all casinos should be harmonised on product.
112
73 percent of the adult population participated in gaming

in the previous year.
Excluding participants in the National Lottery Draw, 53
percent of adults had participated in some other form of
gambling.
Only one activity, football pools, decreased in popularity
between the survey years of 1999 to 2010.
Smoking Ban
From July 1, 2007, all public places and workplaces became
smoke-free, with a very limited number of exemptions.
Taxation
The UK Gaming Duty, which applies to land-based casinos, is
calculated on the following basis (effective from April 1, 2012):

The first 1,929,000 of GGY 15 percent.

The next 1,329,500 of GGY 20 percent.
The remainder 50 percent.
There are 2,729 gaming machines in casinos, most of them

(2,682) category B1 machines. These machines generated a profit
of 129m in 2010-2011. There are 6,190 tables (counting roulette
seats as an individual table) in the UK.
The taxation of online gaming on the basis of taxation at the

point of consumption is pending the Finance Bill 2014.
In its submission to the UK Competition Commission regarding

the proposed acquisition of Gala casinos by Rank Group plc,
Genting noted more than half of the bricks and mortar gambling
in the UK is now controlled by two large Malaysian-controlled
companies.
In January 2013, the UK government began a consultation into

gambling machine stake and prize limits with the reintroduction
of the so-called triennial review system.
Slot Machines
A great deal of debate has been generated around the vexed

issue of fixed-odds betting terminals (FOBTs) in UK betting
shops, which critics contend have introduced casino-type
The Gambling Act 2005 does not prohibit foreign operators from
accepting custom from UK residents even if they are not based in the
EEA or white-listed jurisdictions. It simply prohibits such operators
from advertising their websites in the UK or targeting UK residents.
Many UK-based operators have criticised this liberal regime, with
the government only recently recognising the problems with a
model where foreign operators are given a distinct advantage
by not having to pay tax in the UK or meet heavier licensing and
compliance costs.
As of June 2012, 19 of the UKs 20 largest remote gambling
operators are based offshore, according to the DCMS.
The UK government has elected to bring an end to this model
and impose domestic licensing and taxation, introducing a 15
percent gross gambling yield (GGY) tax for all operators by 2014.
GGY is similar to gross gambling revenue, with the difference
being that in addition to stakes any other amount that will
otherwise accrue in connection with the activities authorised
under the licence must be accounted for.
In December 2012, the UK government published the draft
Gambling (Licensing and Advertising) Bill which, if approved, will
introduce a point of consumption licensing system for remote
gambling in the UK.
113
Parliamentary hearings have now finished and the Gambling

(Licensing and Advertising) Bill 2013 is currently awaiting a
second reading in parliament. If it is passed into law, the bill may
face a legal challenge from operators that stand to lose out from
a point of consumption regime.
A number of Londons high-end casinos have now begun to
provide live dealer gaming online to their clients from their UK
premises.
114

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ABOUT THIS REPORT

GamblingCompliance Research Services

The ECA, the European Casino Association (www.

The main purpose and objective of the ECA is to address

Collect and provide information on casino operations and

Track gambling legislation and regulation across

Contact us to find out more: research@gamblingcompliance.com

ECAS EUROPEAN CASINO INDUSTRY REPORT

USE OF INFORMATION WITHIN THIS REPORT

European Casino Industry Report

ECAS EUROPEAN CASINO INDUSTRY REPORT

Casinos Seeing Signs of Recovery

US Building Boardwalk Empire on Belgian Inspiration

Europe Tempted by Singapore Sling

Europes Casinos Battle Online Tax Mismatch

European Casino Industry Report

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ECAS EUROPEAN CASINO INDUSTRY REPORT

CASINOS SEEING SIGNS OF RECOVERY

tight focus on operational efficiencies and

Nearly five years on from the start of an

Some countries are picking up or stabilising and

Goudsmit contends that casinos across Europe have been hit to

eight of these leading countries posted year-on-year

Now Italys largest casino by turnover, Campione dItalia, close

Still, many thousands of disconnected machines have since

In a clear sign of the turbulence still battering the industry, all

European Casino Industry Report

Still, in Italy, the casinos, seeking increases in visitation at a time

Greek casinos have not shared in the rebound in tourism

European Casino Industry Report

ECAS EUROPEAN CASINO INDUSTRY REPORT

ECAS EUROPEAN CASINO INDUSTRY REPORT

US BUILDING BOARDWALK EMPIRE ON

lthough it is early days, US gambling jurisdictions appear

Belgium introduced nine A+ licences, which cover a wide

The boss of Circus Group added that it was absolutely fair

Many EU countries have rejected the so-called licence plus model

The strategy of Circus, which operates casinos in Spa and Namur

We felt we could not compete with Microgaming or Playtech,

Although they are 5,000 kilometres and a cultural ocean apart,

Behnam Dayanim, a gaming attorney in Washington, D.C.,

Atlantic Citys attractions now include online gaming.

Dayanim said he would be surprised if New Jersey regulators

In every case, as in Belgium, established online gambling

Its a new era, a new game.

California is currently considering legislation that would limit

The casino industry is suffering a lot. Most people will not

Secondly, there is a higher comfort level among regulators with

New Jerseys Planned Online Partnerships

Trump Taj Mahal

Source: GamblingCompliance, company news

European Casino Industry Report

ECAS EUROPEAN CASINO INDUSTRY REPORT

ECAS EUROPEAN CASINO INDUSTRY REPORT

EUROPE TEMPTED BY SINGAPORE SLING

Governments in all three countries have taken steps to re-write

ome of the worlds largest casino operators are now

In Madrid, the regional parliament passed a law at the end of

European Casino Industry Report

Its something we have to think about at a time