A narrow 3-2 ruling
Finland’s Supreme Administrative Court (Korkein hallinto-oikeus, KHO) has ruled that the Tax Administration cannot treat each spin on an offshore online slot machine as a separate taxable event. The court decided the case by a narrow 3-2 majority, ordering the Tax Administration to calculate taxable income per gaming session instead of per spin.
The distinction matters because a single session can contain hundreds or thousands of spins, each producing its own small win or loss. Taxing every spin in isolation meant the Tax Administration could assess tax on individual winning spins inside a session a player ended up losing money on overall. Grouping the calculation by session narrows that exposure. It does not remove it.
The session-based approach still works against players. Losses from one session cannot be offset against profits from another, so a player can lose money overall across a period of play and still owe tax on the winning sessions within it.
Who the tax targets
The spin-by-spin framework applied to operators licensed outside the European Economic Area, including in jurisdictions such as Curaçao, that take bets from players in Finland without a local licence. Finland currently runs a state monopoly over regulated online gambling through Veikkaus. Finland’s president approved the country’s new licensing law in January 2026, and a licensing process is now underway ahead of a market opening scheduled for July 2027. Unlicensed offshore operators remain the Tax Administration’s main target for now.
With the ruling in place, the Tax Administration must revise its assessment practice to match the court’s interpretation. The decision does not touch how Veikkaus or future licence holders are taxed once the new regime takes effect.
Industry and legal reaction
Miika Härkönen, a lawyer at the Finnish Taxpayers’ Association, welcomed the decision.
“The most important thing about the ruling 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.”
Antti Koivula, Chief Compliance Officer at Hippos ATG, called the previous approach absurd in a LinkedIn post.
“Finland’s Supreme Administrative Court has partly reined in the Tax Administration’s absurd spin-by-spin approach to taxing online slot games operated outside the EEA. The Court held that taxable income must instead be determined for each session of play. 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.”
Koivula added that a separate ruling on the taxation of professional sports betting is expected shortly, a case that could carry similar weight for bettors and operators outside the EEA.
A licensing framework still under debate
The ruling lands as Finland works through the design of its new licensed online gambling market, due to open in July 2027. Some industry figures are still questioning elements of the proposed framework, including a cooling-off period for players and a ban on affiliate marketing. Critics argue both measures could push players toward unlicensed sites rather than the regulated market Veikkaus and future licence holders are meant to serve, weakening channelisation once the licence regime takes effect.
Channelisation, the share of Finnish gambling spend that flows through licensed operators rather than offshore sites, is the metric the new regime will be judged on. A tax rule that still lets the Tax Administration collect from winning sessions, combined with marketing restrictions that limit how licensed operators can compete for players already using offshore sites, gives operators and lawmakers a reason to revisit both questions before licensing terms are finalised.
The Tax Administration has yet to say when it will publish revised guidance for offshore slot taxation. The pending sports betting ruling, and how licensing terms are finalised before the 2027 opening, will shape how much of the current offshore market the new regime actually pulls onshore.
Source: Supreme Administrative Court of Finland
