Finland's Supreme Administrative Court Lets a Professional Bettor Deduct His Losing Stakes

Finland's highest administrative court has ruled that betting run as a systematic, expert, income-earning activity is taxed on its net result, not bet by bet. It overturns the Tax Administration's long-held line nine months before the licensed market opens and the tax treatment of unlicensed play gets harsher.

• Finland's Supreme Administrative Court (KHO) ruled on 1 October, in precedent KHO:2026:79, that a professional bettor may deduct all his stakes on bets with operators outside the European Economic Area, losing bets included, from his taxable income
• The bettor, "A" in the ruling and named by trade press as Antti Koivula, placed 2,145 such bets in 2020, staking €365,606 and receiving €406,713, a profit of €41,106
• The Tax Administration had allowed only stakes on winning bets and added €112,369.48 to his 2020 income; the court annulled that, removed a €1,154.60 tax increase and ordered the authority to pay his €5,820 costs
• The court held his betting was not a business but an income-generating activity, resting on research and market knowledge as well as chance, but it set no threshold for who else qualifies
• The ruling follows an August decision taxing offshore casino play session by session, and lands before Finland's licensed market opens on 1 July 2027, when winnings from unlicensed operators serving Finns become taxable even inside the EEA

Finland's Highest Administrative Court Rejects the Bet-by-Bet Rule for Professional Bettors

The Supreme Administrative Court (Korkein hallinto-oikeus, KHO) published precedent KHO:2026:79 (diary number 409/2026) on 1 October. It concerns the 2020 taxation of a bettor identified as "A", who built his activity on information gathering, analysis and finding pricing errors in bookmakers' prices on Finnish football, spending 50 to 100 hours a week on it in busy periods and 30 to 50 in quieter ones. Professional bettor Antti Koivula has said publicly that the case is his, according to SBC News and iGaming Express.

Only his betting outside the European Economic Area (EEA) was in dispute. Under Section 85 of the Income Tax Act, winnings from lotteries run in Finland or lawfully in another EEA state are tax-free, so winnings from non-EEA operators are taxable earned income in Finland. In 2020 he placed 2,145 such bets, staking €365,606 and receiving €406,713, and declared €41,106 as income.

The Tax Administration (Verohallinto) reopened his assessment in September 2022 and added €112,369.48 to his income. It applied its published position on non-EEA betting: the stake on a winning bet is deductible from that bet's winnings, but stakes on losing bets are non-deductible living expenses under Section 31(4) of the Income Tax Act. The Board of Adjustment upheld that in February 2024, citing precedent KHO 2022:60, and the Helsinki Administrative Court agreed in December 2025, reasoning that each bet is a separate event and a lost stake does not change the chance of winning the next.

The Court Finds Skill and Scale Make Betting an Income-Generating Activity

The KHO reversed both. It held that using betting services offered by others is not a business under the Business Income Tax Act. But it found that A's success rested partly on chance and partly on his information gathering and knowledge of the betting market, and that, given the scale and planned nature of the activity, he had pursued it with a stable purpose of earning income. It was therefore income-generating activity (tulonhankkimistoiminta), and he could deduct the full €365,606 in stakes. The court sent his other claimed costs, including office, internet, travel and match tickets, back to the Board of Adjustment.

Koivula wrote on LinkedIn that the case "determined the tax treatment of professional bettors in Finland, both now and going forward", as quoted by iGaming Today. He has said the old approach could have produced a tax bill of about €166,000 against a profit of about €41,000, according to SBC News, a figure not in the decision. Tax lawyer Miika Härkönen, who assisted him through Verotieto Oy, owned by the Finnish Taxpayers' Association, told Taloustaito that poker has long been accepted as capable of being income-generating activity and that the ruling brings betting into line. Koivula, Chief Compliance Officer at Hippos ATG, noted that the ruling sets no minimum hours, stakes or income.

Finland Now Taxes Professional Bettors on Profit and Casino Players by Session

The ruling sits uneasily beside the KHO's August decision on offshore casino play. On 13 August, in ruling 2055/2026 upholding the Central Tax Board's advance ruling KVL 39/2025, the court held that a player on a Curaçao-licensed casino cannot net wins and losses over the tax year, according to PwC Finland. It replaced the Tax Administration's spin-by-spin approach with netting within each playing session, but losing sessions remain non-deductible, so a player who loses over the year can still owe tax. The court split three to two, according to iGaming Expert. The line now runs between chance and skill: a profitable, systematic bettor is taxed on what he earned, while a recreational slot player who loses money can be taxed on winnings he never kept. In a 2025 case cited by the law firm Hannes Snellman, a non-EEA casino player who won about €15.6 million and lost about €15.7 million was taxed on the winnings.

The 2027 Market Turns a Tax Ruling Into a Licensing Question

Under the reform, winnings from licensed operators are tax-free, but winnings from an EEA operator that makes its games playable in Finland without a Finnish licence become taxable, according to Hannes Snellman. The firm warned that under the bet-by-bet rule professional betting "may become financially non-viable in Finland" if established betting firms did not take licences. The KHO has removed much of that risk for anyone who can show income-generating activity, and Koivula has argued it could help professional betting continue once the market opens. The reform's tax rules were designed, the firm says, so that either the operator or the Finnish player pays tax in Finland, which in practice favours licensees; for the small group of professionals who rely on high-limit books, staying with an unlicensed operator now costs a tax on net profit rather than on gross winnings.

The Tax Administration Must Now Define a Professional

The decision sets the principle but not the boundary: A had bet for a living for a decade, and the court did not say how much less would do. The Tax Administration's published position still says losing stakes on non-EEA bets are never deductible, so it will have to rewrite that guidance and decide case by case who qualifies. Bettors taxed under the old rule may seek correction: the ordinary window is three years from the start of the year after the tax year, so 2023 assessments remain open until 31 December 2026, as Taloustaito and iGaming Today report. Until criteria are published, the advantage lies with bettors who can document their activity as thoroughly as A did.

Finland has accepted that betting can be work. Its tax system now has to explain why a profitable professional is taxed on his net gain while a losing casino player can still be taxed on money he never kept.