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Ability to reduce tax burden to attract investors

The Italian gambling market is a mature, highly regulated ecosystem with a powerful offline and online infrastructure, strict rules for responsible gambling and advertising restrictions. There is investment appetite in the sector, but it is constrained by a high cumulative fiscal burden (GGR taxes/turnovers, fees and licenses), compliance costs and marketing constraints. The question is - is it possible to design a selective reduction in the tax burden in order to attract capital without reducing budget revenues and without weakening control? The answer is yes, assuming a "smart architecture" of incentives and linking benefits to investment, employment and transparency.


1) Goals and principles of reform

1. Investment, not just "cheap bets." Benefits should encourage CAPEX/OPEX to Italy: data centers, live game studios, R&D, local tech teams, cybersecurity, Responsible Gaming.

2. Neutrality for budget. The decrease is offset by base expansion (de-tenization, turnover growth, re-patriation of players from the gray market) and conditional payments (clawback) if KPI is not achieved.

3. Pointedness and reversibility. Time regimes (3-5 years) with annual re-evaluation of effectiveness and automatic folding when metrics are rejected.

4. RG-primacy. No incentive should undermine the protection of players: benefits - only when meeting strict KYC/AML/RG standards and technological audits.


2) Basic load reduction tools

2. 1. Targeted reduction in GGR tax rate (or fees) for new investments

To: operators, content providers, live game studios, payment and risk platforms that open/expand production and tech facilities in Italy.

How: reduced coefficient to the basic GGR rate for a limited period (for example, -X pp) when the conditions for CAPEX, workplaces, IP/data localization are met.

Stop conditions: KPI failure → automatic return to base rate and clawback.

2. 2. Investment tax credit (ITC)

Base: CAPEX for infrastructure (data centers, studios, content delivery networks), green modernization, cybersecurity, RG analytics.

Mechanics: return on part of investments through a decrease in tax liability within 3-4 years.

2. 3. R&D super calculations

Focus: RG behavioral analytics, anti-fraud models, live telemetry, latency minimization, SIM racing physics, omnichannel accessibility interfaces.

Condition: local development team and transfer of part of IP to Italian jurisdiction.

2. 4. Regional preferences (Mezzogiorno and industrial clusters)

The point: additional credit/rate cuts in exchange for opening studios/support centers in southern regions and small towns with high unemployment.

Effect: diversification of employment, development of local ecosystems and educational programs.

2. 5. "Green" module

For what: energy-efficient data centers, the purchase of renewable energy, logistics and equipment disposal.

Benefit: ITC bonus or separate "green" deduction.


3) Application models (scenarios)

S1. "Entry point" for new investors

Reduced GGR rate only for new licenses/sites with minimum investment and occupancy threshold.

KPI: number of jobs (FTE), salary level, share of local contractors, CAPEX volume.

S2. Quality Upgrade for Incumbent Operators

Temporary reduced GGR ratio in exchange for:

1. transfer of computing power to Italy, 2. implementation of standardized RG-UI and behavioral "coolers," 3. latency and anti-fraud certification.

KPI: decrease in the number of RG/fraud incidents, increase in data localization, live stability.

S3. "Export Content"

Credits for studios creating Italian games/show formats with exports to the EU/world.

KPI: export revenue, number of releases, international licenses.


4) How to maintain fiscal sustainability

1. Broad base vs. high rate. Lower rate - higher incentive to "play in"; the increase in legal turnover partially compensates for the decline.

2. Clawback clauses. If KPIs are not achieved, the benefit is automatically converted into an installment tax.

3. De-tenization bonus. Additional reduction for those who document traffic from the illegal segment (reduction in the "cannibalization" of the budget).

4. Conditional "compliance module." Benefits are indexed up for companies with impeccable RG/AML statistics, and down for violations.


5) Risks to close

Disruption of competition. Benefits - open, transparent, with equal access when the conditions are met; exclude "individual gifts."

Regulatory arbitration. Prohibition on the use of benefits for dumping in UX/bonuses; control of pricing policy and promotional frequency.

RG effects. Strict communication ceilings, age-gates, "quiet mode" of fluffs, active limits by default; audit sessions.

Financial risks. Multi-level anti-fraud, source of funds for high-rollers, payment liquidity stress tests.

Reputational costs. Public reporting on KPI benefits: employment, investments, RG metrics, green indicators.


6) Reform KPIs (measurable benchmarks)

Investments: CAPEX/OPEX in Italy (year-on-year), share of local contractors.

Employment: Net FTEs, median salary in clusters.

De-tenization: an increase in legal GGR, a decrease in the share of the illegal monitoring segment.

Quality of service: uptime live during peak hours, medium TTS (time-to-stake), fault tolerance.

RG: proportion of users with active limits, frequency of "timeouts," decrease in complaints.

Export: Italian studios revenue from international releases.


7) 12-18 month roadmap

Stage 1. Design (0-3 months)

Economic and legal model of benefits; determination of KPIs; creation of an interdepartmental group (economy, ADM, labor, ecology, figure).

Stage 2. Pilot (4-9 months)

Limited number of participants (new and current), mandatory compliance audit, digital reporting and monitoring platform.

Stage 3. Scaling (10-18 months)

Expanding the list of benefits and regions, launching an export module for content studios, publishing the first annual report.

Stage 4. Audit

Reconciliation of KPIs and automatic adjustment of parameters (rates, thresholds, bonuses/maluses).


8) What key stakeholders will get

State: new investments and jobs, de-tenification, quality control and RG without budget "holes."

Operators and providers: predictable rules of the game, payback of CAPEX, incentives for technological superiority.

Cities and regions: development of technical clusters, tourism around studios/museums, educational trajectories.

Players: safer and more stable product, transparent conditions, better protection of interests.


9) Short checklist for legislator and regulator

1. Tie benefits to real investment and employment, not turnover per se.

2. Sew RG and AML conditions "default" into each benefit.

3. Oblige public reporting on KPIs with an annual update of parameters.

4. Introduce clawback and anti-dumping restrictions.

5. Simplify administrative procedures: one "entry point," digital offices, predictable deadlines.


Inference.

Reducing the tax burden in Italian iGaming can be a powerful magnet for investors - if it is designed as conditional, measurable and reversible. Investment loans, targeted rate cuts on GGR, R&D and green super accounts, regional preferences and a strict RG circuit create a balance between capital inflows and public interest protection. Such a model does not "cheapen" risk, but buys quality: technology, jobs and exported products, strengthening Italy's position as a mature and responsible gaming market.

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