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A Balanced Take on Optimal RTP for New Turnover Taxation in Germany

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A Balanced Take on Optimal RTP for New Turnover Taxation in Germany
A Balanced Take on Optimal RTP for New Turnover Taxation in GermanyReading Time: 4 minutes

 

What should be the optimal return to player (RTP)? This is a hotly debated question in the German gambling industry following the changes in the turnover taxation that are scheduled to come into force from 1 July 2021.

While several figures and many theories have been advanced, we found particular LinkedIn post by Robert Lenzhofer, Co-Founder and CEO of Hölle Games, particularly well-balanced and insightful.

We are reproducing the post with minor changes here, with permission from the author. You can find the original post here.

Over to Mr. Lenzhofer now…


I have published a LinkedIn poll recently with the title: “If/when Germany introduces the 5.3% turnover tax, what RTP rate is best suited considering both game-play and effective tax-paid?”

After one week and 120 votes from industry experts, the poll showed the following result:

Picture of poll outcome. 90-92% RTP gets 52% votes. 87-89 gets 33%. 84-86 gets 8%. 81-83 gets 8%. Total 120 vots. Poll is closed

There are a few ways of looking at this, but I think the key take-away is that the industry this poll represents is fairly evenly split between above 90% RTP and below 90% RTP.

The tax explained

First, to ensure we are on the same page, a quick explanation of the tax proposed:

Currently a 5.3% tax on turnover has been proposed and a draft-legislation does exist. I won’t go into the politics and the thinking behind this, but rather try to analyze the numbers.

A 5.3% tax on every bet being placed on an online slot means an operator can not offer an RTP over 94.7%. At 94.7% RTP, the operator would break even exactly on a bet-level, but obviously would lose money as marketing, employees and general operation have to be financed somehow. Considering financial overhead in any operation, that means the maximum RTP a casino is technically able to offer while avoiding bankruptcy is probably around 93% or more likely at 92%. This is the top ceiling and at the same time too high to be profitable.

Now, there is a bit of uncertainty and I’m also not entirely sure if the number to calculate against is 5.3% or rather 5.033%. The tax is 5.3% on turnover, meaning a 1 EUR bet causes a tax of 5.3 cents, which totals to 1.053 EUR. The tax-portion of 1.053 EUR is less than 5.3%. 100*5.3/(100+5.3) = 5.033 resp. 5.033%. I do calculations here in this document based on 5.3%.

How to balance RTP and profitability

We’ve established above that 93% or 92% is the top ceiling, but where is the bottom?

The table below shows how a Slots-operator will be taxed, calculated into the GGR-equivalent %-age number and cross-referenced with RTP. For reference, many other jurisdictions in Europe offer a GGR-based tax-rate of around 20%. As you can see from the table below, the 5.3% tax-rate on turnover wouldn’t be so bad, if players would accept 80% RTP. At 80% RTP, the GGR-equivalent tax-rate is 26.50% and thus a competitive tax-rate.

Table describing various tax rates with respect to betting amount

The coloring I have done here may be slightly biased, especially in terms of RTP so please take with a grain of salt. But if you roughly accept that the red-area you want to avoid on the RTP and on the GGR-% side, then you end up with an RTP-bandwidth between 84% and 91% to play with.

Further, and again granted you accept the coloring, an operator obviously wants to find an RTP in the green and a GGR-% in the green. Here we arrive at 88% and 89% RTP.

Now, a lot has been written that players will not accept such low RTP’s as say 84%. There are counter-arguments made that in land-based slots the RTP is exactly at that level and actually 88% is on the higher-end in land-based casinos.

On the other hand, for many market-participants the number “9” is a psychological blocker. Players, Affiliates and a couple of Slots-Studios I speak to feel very anxious offering product below 90% as this number still feels somewhat close to the industry-average of 94 to 97%. 89% sounds very different than 90%, although it is “just” 1% in RTP dropped.

Sportsbook vs. Casinos

It will be interesting to watch if Sportsbook or Sports-led brands will choose a differing RTP-rate than Pure-Play Casinos. A Sportsbook can more easily stay on a higher RTP and just pause all short-term expenses (bonus, marketing, etc.) and focus on cross-sell. A pure-play Casino will have to look a lot more closely on bottom-line and in my opinion will have a hard time offering e.g. 90% RTP-Slots as the GGR-equivalent tax-rate is 53%.

Game-Mechanics?

Will there be new Game-Mechanics invented to combat this problem? Looking at the table above again, the second column states how many spins a player on average can make until 1 EUR is spent depending on the RTP-Level. At 95% RTP this is 20 spins. Now, if a Game-Mechanic can be invented that provides a low mathematical RTP while at the same time provides a similar amount of real spins, then this could be a solution to the problem.

Conclusion

The above explanation is in no way complete – there are actually interesting studies which analyze how much an RTP is “felt” by the player and there is probably very good data the land-based industry has to offer.

But, to move away from being neutral, here’s what I personally think: The reality will be that everyone will push the RTP down and experiment with the lowest acceptable RTP as this maximizes their income. As such, come 1st of July, we’ll see a lot of RTP’s experimented with. Imagine you are a pure-play casino and you can provide a Game-Mechanic that feels good to the player and has a nice session length, while staying at or below 40% GGR-equivalent-tax. I believe things start to fall apart financially for an operator at 40% tax-rate. If you own your own media-assets and have good deals with your suppliers and run a tight operation then a 40% tax is possible to do really well in Germany. That means, the average-RTP across the portfolio will have to be around 87-88%. I think you can mix in 91% games into the portfolio just so that is part of the portfolio too, but the majority of revenue of the white-market in Germany will in my opinion come from Slots around 88% RTP. And since some games will be mixed in at 90/91% you can expected some slots to be mixed in at 84/85% rate as well.

 

George Miller (Gyorgy Molnar) started his career in content marketing and has started working as an Editor/Content Manager for our company in 2016. George has acquired many experiences when it comes to interviews and newsworthy content becoming Head of Content in 2017. He is responsible for the news being shared on multiple websites that are part of the European Gaming Media Network.

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Osborne Clarke advises Shore Capital on £205 million IPO of Winvia Entertainment, marking renewed momentum in London markets

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International law firm Osborne Clarke has advised Shore Capital on Winvia Entertainment plc’s £205 million AIM IPO and associated £40 million institutional placing. Shore Capital acted as nominated adviser, sole bookrunner and sole broker.

Technology focused business Winvia Entertainment is the second largest prize draw operator in the UK by market share and owns the brands Best of the Best and Click Competitions, through which players can play for prizes including cars, luxury watches and holidays.

Outside the UK, the company is focused on the fast-growing and regulated Romanian online gaming market, where it is a top three online casino operator, operating a multi-brand strategy including own brands such as Princess Casino, Royal Slots and Luck, white label brands such as Magnumbet, Cashpot and Excelbet, and a majority owned poker business.

Winvia Entertainment intends to use the net proceeds of the placing to fund acquisitions in the large but fragmented UK prize draw sector. It has been building a pipeline of other opportunities and is in discussions with several potential acquisition targets to allow it to consolidate its position in this rapidly growing market.

Admission and trading in the company’s ordinary shares on AIM took place on the 3 November 2025 at 8:00 a.m.

The IPO represents a significant AIM admission in H2 2025 and highlights the renewed interest in UK tech and digital-entertainment flotations. It follows commentary that the London listing market may be turning a corner, with several listing announcements and a strengthening pipeline emerging in recent weeks.

Commenting on the transaction, Ed Nisbet, Associate Director at Osborne Clarke, said: “We are delighted to have assisted the Shore Capital team in relation to the IPO of Winvia Entertainment. Both the UK and Romanian markets that the group is focused on offer exciting opportunities and this IPO perfectly positions Winvia to build on its existing strength to take advantage of these. This transaction, together with general market activity and our increasing pipeline of opportunities, is also demonstrative of the increased momentum in UK capital markets.”

Jonathan King, Partner at Osborne Clarke, added: “The Winvia IPO showcases the breadth of Osborne Clarke’s capital markets expertise – from advising on complex cross-border structures to supporting clients at every stage of their growth.”

Osborne Clarke’s Corporate team, which is ranked in the top tiers by both Chambers UK and Legal 500 UK for AIM, is considered a go-to practice for many companies in the tech, media and comms sector. Its clients range from global businesses to fast-growth start-ups and market challengers. The team advises at every stage of company development across all corporate issues, from equity and debt fundraisings to strategic M&A, IPOs and JVs.

 

The post Osborne Clarke advises Shore Capital on £205 million IPO of Winvia Entertainment, marking renewed momentum in London markets appeared first on European Gaming Industry News.

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MIXI Global Investments, Nazara Technologies & ChimeraVC join forces to launch ‘LVL Zero’ gaming incubator in India; Google Play joins as Knowledge Partner

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With a total equity free grant pool of USD 100,000, LVL Zero will fast-track product execution, provide targeted mentorship, and enable investor and publisher readiness within 100 days

Following the Promotion and Regulation of Online Gaming Act, 2025, the incubator aims to empower India’s gaming leap by supporting 100+ high-performing startups over the next five years

MIXI Global Investments, Nazara Technologies & ChimeraVC have officially joined forces to launch LVL Zero, a gaming incubator designed to help India’s gaming startups accelerate product execution and achieve investor and publisher readiness within 100 days. The initiative is supported by Google Play, which joins as the Knowledge Partner, offering technical mentorship, platform guidance and developer best practices.

As per the India Gaming Report 2025, India is home to 16.63 crore gamers today, with the number expected to reach 24.68 crore by 2027. As the nation’s gaming audience continues to expand, many new startups across diverse portfolios have emerged, yet few have scaled to global publishing, live operations, or sustainable business models. With global investors and publishers increasingly viewing India as a hub for creative talent and innovation, LVL Zero brings together some of the biggest names in the industry to bridge this gap. Offering equity-free grants and open to all game developers in the ecosystem, the incubator will provide mentorship, access to tools, and support to help Indian startups build sustainable ventures and compete on a global stage.

What LVL Zero Offers

  • LVL Zero is built to fast-track startups from concept to investor and publisher readiness in 100 days through structured, measurable goals.
  • Each cohort startup is matched with mentors who align with their current challenge whether it’s game design, development, analytics, or live-ops.
  • A USD 10,000 equity-free grant for 10 startups each, along with access to global and Indian mentors, tools, platforms, and growth infrastructure provided by partners.
  • LVL Zero connects developers with publishers, investors, and ecosystem partners to open pathways to distribution and funding.
  • The programme focuses equally on product quality, data-led decision-making, business scalability, and product narratives, preparing startups to operate at global standards.

How LVL Zero Will Work

  • The LVL Zero framework is designed to compress years of learning and growth into a focused 100-day execution cycle. It is an outcome-driven sprint with defined phases and checkpoints.
  • Three-phase structure: Each team starts by pinpointing its biggest challenges and goals, builds through guided mentorship, testing and feedback cycles, and finishes ready for publisher reviews, investor outreach, and scale-up opportunities.
  • Hands-on mentorship: Teams work closely with domain specialists from across the globe across game design, production, user acquisition, monetisation, and business strategy and more.
  • Sprints and reviews: Regular product reviews and data checkpoints ensure measurable progress toward publishing and funding readiness.
  • Demo Day: The cycle concludes with a Demo Day, where startups pitch to a curated panel of publishers, investors, and strategic partners for potential capital, distribution and growth opportunities.
  • Ecosystem support: After Demo Day, teams remain connected to the LVL Zero network for ongoing mentorship, partnership and fund raising introductions.

The partners & hosts of LVL Zero

As a firm specialising in games, tools and infrastructure, Chimera VC brings its early-stage, product-first investment approach to LVL Zero. The firm focuses on gaming, tools and infrastructure startups, backing founders early, helping them ship fast and scale globally.

“With Chimera, we’ve always worked with founders at Level 1 – the seed stage where conviction meets capital. LVL Zero allows us to start even earlier, at the stage where belief forms before traction and ideas are still taking shape. Most founders meet investors once they have momentum; LVL Zero lets them meet conviction first. It completes the loop for us, helping founders start earlier, think globally, and build more sustainably.” said Krish Anurag, Managing Partner at Chimera VC.

Nazara Technologies, India’s leading diversified gaming company and only publicly listed gaming company, which has its own publishing division known as Nazara Publishing, is a game publishing division of Nazara Technologies. It adds its publishing expertise, market experience, and global reach to the initiative. With a diversified portfolio across mobile gaming, esports, and sports media, Nazara has been instrumental in shaping India’s gaming landscape.

Nitish Mittersain, Joint MD & CEO, Nazara Technologies, explained, “At Nazara, we have always believed that India’s gaming story will be written by its startups. With LVL Zero, we are helping turn ambition into execution. This collaboration allows us to bring publishing experience, analytics insights, and go-to-market knowledge directly to developers who are ready to take the next leap. The future of gaming in India will depend on how well we empower startups to build and own their success stories.”

MIXI Global Investments (MGI) is the corporate venture capital arm of MIXI, Inc., based in Tokyo and known for its popular mobile game IPs and community-focused live operations. It brings global expertise and networks to help Indian startups engage with international markets and partners.

“We’ve been impressed by the energy and creativity of India’s game developer community. Through LVL Zero, we aim not only to invest but also to contribute to the country’s broader ecosystem—supporting emerging talent to grow and building a lasting bridge between Japan and India’s gaming industries,” said Tomoharu Urabe, Managing Director of Investments at MIXI Global Investments, Inc.

As Knowledge Partner, Google Play will provide participating teams with developer resources, technical mentorship and insights on discovery, retention and monetisation. The platform’s deep understanding of developer growth and user engagement will help startups maximise their reach and success.

The launch of LVL Zero comes at a time when India’s gaming ecosystem is growing rapidly, supported by the Promotion and Regulation of Online Gaming Act, 2025, expanding 5G networks and the mainstream acceptance of gaming as a viable career option. The incubator aims to support more than 100 high-performing startups over the next five years, nurturing a new generation of Indian gaming startups ready for global markets.

By focusing on execution, mentorship and access to the gaming industry, LVL Zero bridges a critical gap in the ecosystem, helping startups move from early-stage prototypes to globally competitive products. As more Indian teams build with global benchmarks, the impact will strengthen the entire industry: better talent retention, greater investor confidence and increased publisher trust in Indian game IP.

 

The post MIXI Global Investments, Nazara Technologies & ChimeraVC join forces to launch ‘LVL Zero’ gaming incubator in India; Google Play joins as Knowledge Partner appeared first on European Gaming Industry News.

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PAGCOR net income up 49% to Php14.32B in first nine months of 2025

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The Philippine Amusement and Gaming Corporation (PAGCOR) today announced that its net income in the first three quarters of the year has reached Php14.32 billion, a 49% increase from the Php9.63 billion in the same period last year.

Total revenues from January to September was at Php84.09 billion, rising 5.87% year-on-year from Php79.43 billion. Gaming operations accounted for Php75.93 billion of the total revenues while other related services and other income contributed Php8.16 billion.

PAGCOR Chairman and CEO Alejandro H. Tengco said the strong revenue performance highlights the positive impact of the agency’s governance and modernization initiatives.

“Our financial performance is a clear reflection of PAGCOR’s renewed focus on governance, digital transformation, as well as sustainable and responsible gaming,” Mr. Tengco said.

The agency’s total contributions to nation-building (CNB) likewise rose 11% to Php54.26 billion from Php48.88 billion during the period in review.

Out of the total CNB, two-thirds or Php36.06 billion went to the National Government as mandated by Presidential Decree 1869. This share, which accounts for 50% of PAGCOR’s gaming revenues minus 5% franchise tax, also covers allocations for the Dangerous Drugs Board and the Philippine Health Insurance Corporation (PhilHealth).

PAGCOR also paid Php3.79 billion in franchise taxes and Php609.87 million in corporate income taxes to the Bureau of Internal Revenue (BIR).

The agency likewise allocated Php11 billion for its socio-civic projects, including remittances to the President’s Social Fund.

The Philippine Sports Commission received its mandated 5% share worth Php1.80 billion, an 8.66% increase from the same period last year, while athletes and coaches who won in international sports competitions received Php26.54 million under the Sports Incentives and Benefits Act.

Other mandated PAGCOR beneficiaries include the Board of Claims, which received Php142.42 million, and the Renewable Energy Trust Fund which got Php201.47 million.

Cities hosting Casino Filipino branches also received a total of Php508.20 million in revenue shares.

Mr. Tengco said PAGCOR remains committed to aligning its growth with public service goals.

“Every peso that PAGCOR earns goes back to the people through classrooms, health facilities, disaster response programs, and other community projects,” he said. “Our focus is to sustain this momentum while ensuring that the gaming industry continues to operate responsibly and contribute to national development.”

 

The post PAGCOR net income up 49% to Php14.32B in first nine months of 2025 appeared first on European Gaming Industry News.

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