KHO ruling Koivula: court allows deduction of betting losses in 2020

By decision of 1 October 2026, the Korkein hallinto-oikeus (KHO) ruled in favour of Antti Koivula and authorised the tax deduction of the 365 606 € he used on bets placed outside the European Economic Area during 2020. The court considered Koivula’s activity in that period to be a "tulonhankkimistoiminta" (income-generating activity) and annulled the previous tax adjustment; the decision also obliges the Finnish Tax Administration, Verohallinto, to reimburse 5 820 € in legal costs.

What the KHO did and why it matters (KHO ruling Koivula)

The KHO ruling focuses on the characterization of Koivula’s betting activity: the court concluded that the volume and planning of his wagers amounted to an activity aimed at generating income. In 2020 Koivula recorded 2 145 bets, with 365 606 € in stakes and 406 713 € in returns, leaving a net positive result of approximately 41 100 €.

The Finnish Tax Administration, Verohallinto, had initially considered deductible only the stakes associated with winning bets and rejected the stakes of lost bets. That interpretation substantially increased Koivula’s taxable base and led to a tax correction whereby, in 2022, Verohallinto increased his employment income by 112 369,48 € and imposed a tax surcharge of 1 154,60 €.

Fiscal context and key figures

Koivula, who is a lawyer specialised in gambling and a former professional bettor, currently serves as compliance director at Hippos ATG Oy. In his public testimony he said he had already paid about 12 000 € on the actual net profit of ≈41 100 € and faced an additional claim that was initially about ≈57 000 €, an amount he estimated had grown to ≈75 000 € with interest and surcharges. The case had a significant personal and financial impact: Koivula said he lacked liquidity to meet extraordinary payments and that his family relied on his income.

In addition to annulling the tax correction and its surcharge, the KHO returned the obligation to Verohallinto to reimburse legal costs of 5 820 €.

Scope of the ruling: which costs remain in dispute

The court explicitly ruled that Koivula was entitled to deduct bets placed outside the EEA in 2020 totalling 365 606 €. Not all items Koivula claimed as deductible were resolved in his favour in this decision. The allowance of certain deductions was remitted to the tax rectification board (oikaisulautakunta). Among the outstanding items are:

• telephone and internet connection costs related to the activity;

• workspace costs and office supplies;

• office and publication expenses;

• business travel;

• tickets to football matches.

The KHO did not set precise quantitative parameters — it did not establish, for example, a threshold of hours devoted to the activity nor a minimum stake amount. The court explained that the assessment must be based on the totality of conduct: systematic nature, persistence and the purpose of obtaining income.

Professional profile of Koivula and how it influenced the decision

Antti Koivula stated in interviews that between 2010 and 2020 his family and he supported themselves through planned betting activity. At the most intense periods he said he devoted between 50–100 hours per week to the activity; in less intense phases, 30–50 hours per week. His focus was on Finnish football matches and detecting odds discrepancies through analysis and information capture.

Although the KHO did not treat the activity as a trade or business (the term "elinkeinotoiminta" was not applied), the court did consider that Koivula’s conduct was sustained and organised and therefore fit the statutory concept of income-generating activity under the income tax law.

"The ruling may give others who operated professionally in the past a basis to review old tax assessments," Koivula said in one of his public statements, according to local media.

Reactions and possible regulatory consequences

Koivula described the ruling as relevant for other professional bettors in Finland. He also suggested that, in view of a possible future national licensing system, the decision could affect how people who have bet professionally are treated for tax purposes. In his comments he expressed interest in improved consumer protection within gambling regulation and criticised customer service practices on extraterritorial platforms.

For operators, suppliers and tax advisers the ruling sets a precedent that will force clearer documentation criteria and a review of how activities of revenue-generating players are classified. It is likely tax advisers will re-examine past files of clients who bet professionally and consider filing appeals or rectification requests.

What operators and advisers should consider (deduction of bets)

• Documentation: keep clear records of stakes, returns, hours and work methodology.

• Market distinction: the ruling applied to bets organised outside the EEA in 2020; market jurisdiction is relevant.

• Case-by-case assessment: the KHO insists on a valuation of the totality of activity, not fixed thresholds.

The judgment also has practical compliance implications for in-house tax and compliance departments at operators and bookmakers, which will need to consider how to respond to historical claims and what evidence is accepted to justify the professional nature of the activity.

Materials and references

The KHO decision is available in the court’s decision database; Finnish media that covered the news include Taloustaito, Nettipokeri.com and Atleetti. For regulatory matters and the impact on public policy, sector stakeholders can follow the discussion in the section of [regulation](/regulation) and in professional analysis in [b2b](/b2b).