Finnish Supreme Administrative Court Rejects Per-Game Tax Assessments for Non-EEA Online Slots

Finland’s Supreme Administrative Court has rejected the tax administration’s strict game-by-game approach to online slot gambling outside the European Economic Area. In a 3-2 majority decision, the court ruled that wider gaming sessions must instead determine taxable income, giving players greater scope to deduct losses from connected bets.

Winnings from gambling within the EEA remain generally tax-free in Finland. The case at issue involved a young gambler who faced substantial tax liability despite overall losses. The ruling strengthens the principle that income tax applies to net income after deductible expenses connected to generating that income.

Session-Based Assessment Replaces Per-Game Calculations

The court placed greater importance on the wider gaming session. Bets from losing games can be deducted in certain circumstances when they belong to the same gaming group, although losses from one session cannot be used to reduce profits from another.

Miika Härkönen, tax lawyer at the Finnish Taxpayers’ Association, said: “The most important thing about the decision is that the Supreme Administrative Court did not accept the Tax Administration’s view that each game should be viewed as a completely separate event.” He gave the example of a player who takes breaks to eat or use the bathroom during Saturday play, saying those activities would generally remain part of one session.

Antti Koivula, Chief Compliance Officer at Hippos ATG, described the ruling as a partial restriction of the previous method. Koivula said: “The Court held that taxable income must instead be determined for each session of play (pelirupeama). However, losses from one session cannot be offset against profits from another, meaning that a slot player may still lose money overall while owing considerable tax.”

The practical definition of a session remains important. This limitation means the ruling offers only partial relief.

Impact on Guidance, Reassessments and Pending Reforms

The decision could affect earlier tax assessments made under the previous interpretation. Claims for adjustment can reach three years into the past, meaning a 2023 assessment could still potentially be challenged in 2026. The Tax Administration must update its guidance following the ruling.

As reported by Casino News Daily, Finland’s wider gambling framework remains in development. Commercial gambling licences are expected to take effect on 1 July 2027, while the National Police Board had received 50 applications by June. Each application carries a €29,000 processing fee.

A separate Supreme Administrative Court ruling on professional betting is also expected. That case will examine the treatment of losing bets and whether professional betting qualifies as business or income-generating activity for tax purposes. The current decision arrives at a time when authorities are preparing for these changes, underscoring the need for precise session definitions to balance revenue collection with accurate net-income principles.

Reporting: Casino News Daily

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