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“There should be, in my opinion, a review of the whole ISC or consumption tax framework and find a kind of alignment or a better way to get an income in terms of taxes, but that should be balanced in order to avoid the disruption of businesses and a migration of customers to the illegal market.”
Atucha warns there is a tipping point where higher taxes can undermine channelisation, citing the UK and Germany as important case studies.
“I sometimes wish regulators would look at other cases,” he adds. “I mean, what happened in Germany, what’s happening in the UK.”
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The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.
The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.
Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.
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Members flagged the growing issue of illegal gambling sites’ advertising appearing across social media, an issue the sector in Netherlands has sought to tackle directly through legal action against Meta.
Speaking on behalf of the government, Van Bruggen said: “Meta, especially as one of the parties, but also Google, is really open to this conversation.”
She said the government would receive a report every six months on illegal gambling advertising across these platforms. She insisted the issue should also be dealt with at an EU level, through the Digital Services Act.