Υπουργείο Εθνικής Οικονομίας και Οικονομικών

Δικτυακός Τόπος Διαβουλεύσεων

• Σχόλιο του χρήστη 'Paddy Power Betfair' | 5 Οκτωβρίου 2018, 11:29

  Μόνιμος Σύνδεσμος

  It appears that in conjunction with the proposed Article 25 Sub-paragraph v), which defines other online games of chance as live casino games without a random number generator as well as online poker (peer to peer) and its variants, the provision above would exclude online casinos games that are RNG-based from the scope of the Law. Given that RNG games make up a significant potion on the existing online market, and in order to achieve compliance with EU law, reduce the size of the unregulated market, protect consumers and generate additional tax revenues, it would be preferable to opt for a licensing regime that includes all major online products, i.e. betting (fixed-odds and exchanges), poker and casino games (Random Number Generated games as well as dealer games). Ban on betting exchanges We are disappointed to note that the removal of the ban on betting exchanges has been not included in the draft amendments proposed to the law. We fail to understand why the Ministry has not removed the unjustified ban on one of PPB’s core betting products, for which there remains no compelling rationale. Indeed, having received support from several of the key political and regulatory stakeholders for the removal of the ban and in the absence of any detailed justification for the ban (for which we would be grateful), we can only assume that the interests of certain competitors have prevailed and successfully lobbied to retain the ban. This is very unfortunate and we urge the Greek Government to reconsider its position on this matter, not least because (as we explain below) the Greek state stands to benefit in several ways if it the ban was removed. Moreover, we believe it is in the interests of both PPB and Greek Government to avoid any unnecessary litigation for damages that we may be forced to pursue in the Greek courts should the ban remain in place. Should the ban be lifted, the Greek state stands to benefit in a number of ways:  Financial benefits for the Greek State By preventing Greek players from having access to the betting exchange, and as indicated in the tables in the attached annexes, we estimate that the Greek State will be missing out on approximately €35 million in taxation revenue, licencing fees and other inward investment over 5 years. If PPB was allowed to operate its betting exchange (and the tax on customer winnings is reformed), we would anticipate paying in the region of €12-15 million in tax over 5 years (as shown in Annexes 1 and 2, which show a forecasted minimum of €12.95M in tax revenues), and around €3-4 million per annum in media spend (€25.8M of total investment over a 5-year period with Greek companies in media (as shown in Annex 3), as well as licencing fees that are payable.  Channelling consumer demand and limiting the black market Given the unique appeal of the exchange (e.g. better value, ability to trade), it is important that betting exchanges are included in the regulated offering otherwise consumers will seek alternatives in the black market, which will result in a loss of taxation revenue and lower levels of consumer protection. Betting exchanges will simply complement the existing range of online gambling products in Greece and help to grow the size of the overall market, rather than cannibalise existing products. From PPB’s experience of operating in the UK and other markets, betting exchanges only appeal to a certain category of customers and do not threaten mass-market betting products such as sportsbooks and retail betting. This is indicated by Annex 4 below. Annex 5 demonstrates that the betting exchange makes up a minor portion of PPB group revenues, reflecting the fact that sportsbook products are now the focus for the PPB Group.  Ensuring compliance with EU law and avoiding future legal challenges Greece has never provided a formal justification for the ban on betting exchanges and we believe that the ban is discriminatory and breaches EU law. We have received a detailed legal opinion from a leading barrister in London – Kelyn Bacon QC - that conclusively states that the ban is a clear breach of EU law and that the Greek state could be liable for damages should PPB eventually chose to litigate the ban (something we clearly wish to avoid). We have attached this opinion in Annex 6 of this submission.  International precedent The betting exchange is a unique product that forms an essential part of PPB’s global business. Apart from Cyprus, Greece is presently the only country in the world where an explicit ban on exchange betting is being enforced. Betting exchanges are currently regulated in a great number of international jurisdictions, including the UK, Australia, the United States, Ireland, Malta, Denmark, Spain, Italy, Romania and Bulgaria, while several other countries, such as Colombia, Sweden and The Netherlands have plans to regulate and licence betting exchanges very soon.  Helping to combat crime and illegal activity The betting exchange is one of the most transparent products on the market since it is possible to view both sides (back and lay) of the market. This makes it a hugely effective tool to prevent money-laundering and other forms of financial crime, as well as the prevention of match-fixing and sports betting related corruption. Our industry-leading sports integrity team have pioneered a highly effective system of information sharing arrangements with over 70 sports federations around the world (including IOC, FIFA, UEFA), making us a key stakeholder in the fight against match-fixing and corruption in sport. PPB would be delighted to share its expertise and knowledge in this area to help tackle the growing problem of match-fixing in Greece.