Finnish Court Overturns Spin-by-Spin Tax Approach

Finnish Court Overturns Spin-by-Spin Tax Approach

Finland's Supreme Administrative Court has overturned the Tax Administration's practice of taxing individual spins on online slots hosted outside the European Economic Area, ruling instead that tax must be calculated on a session-by-session basis. 

The court voted 3-2 in favour of changing the previous approach, which treated every single spin on games based in jurisdictions such as Curacao as a separate taxable event.

Miika Harkonen, tax lawyer at the Finnish Taxpayers' Association, said the ruling's core significance is that "the Supreme Administrative Court did not accept the Tax Administration's view that each game should be examined as a completely separate event," according to SBC News, which cited Finnish outlet Taloustaito's initial coverage of the decision.

Antti Koivula, Chief Compliance Officer at Hippos ATG and a prominent Nordic gambling law expert, called the previous spin-by-spin approach "absurd." 

He said the court "partly reined in the Tax Administration's absurd spin-by-spin approach to taxing online slot games operated outside the EEA," and confirmed that "the Court held that taxable income must instead be determined for each session of play."

A Caveat For Players

Koivula added an important caveat for players: losses from one session cannot be offset against profits from another under the new ruling, "meaning that a slot player may still lose money overall while owing considerable tax." 

He also noted that a separate but related ruling on professional sports betting taxation is expected soon.

Taloustaito reported that the Tax Administration now needs to update its policies to reflect the court's decision, though the ruling was described by SBC News as unpublished at the time of reporting, meaning the full text of the judgment was not yet publicly available.


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Why The EEA Distinction Matters

The distinction between EEA and non-EEA operators matters because Finland's tax treatment of the two differs sharply. 

Winnings from games run within the EU/EEA are exempt from tax for Finnish players, as per Vero, the Finnish Tax Administration, while winnings from operators based outside the EEA, such as those licensed in Curaçao, have been treated as taxable earned income. 

This week's ruling narrows how that non-EEA taxable income is calculated, without changing the underlying EEA exemption.


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Part Of A Wider Market Overhaul

The decision arrives as Finland works toward a licensed online gambling market. 

According to the Finnish Government, most provisions of the new Gambling Act take effect on July 1, 2027, ending Veikkaus Oy's decades-long monopoly on online betting sites and certain online gambling products and opening the market to competing licensed operators. Companies have been able to apply for licences with the National Police Board of Finland since March 2026.

Koivula has previously been critical of how Finnish policymakers have handled that transition, particularly the planned ban on gambling affiliates operating in the country from July 2027 onward, which he has said stems from a misunderstanding of what affiliates actually do.

For now, the ruling narrows one specific piece of Finland's tax treatment of offshore gambling activity, without resolving the wider questions around the country's incoming licensing framework. Industry figures including Koivula say there remains, in his words, "a lot of room left to be more precise" once the new regulatory regime takes effect.

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