Betting Industry

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EXECUTIVE SUMMARY ..................................................................................................... 3 RETAIL BETTING OVERVIEW ........................................................................................... 4

SECTOR EMPLOYMENT ....................................................................................................... 5 TURNOVER LEVELS ............................................................................................................. 5 SHOP NUMBERS ................................................................................................................. 6 TAXATION CONTRIBUTION ................................................................................................... 6

Average contribution to Exchequer .............................................................................. 7 PAYMENTS FOR IRISH RACING MEDIA .................................................................................. 8

TAXATION MODELS PROPOSED BY OTHERS ............................................................... 9 A - TAXATION ON CONSUMER ............................................................................................. 9

Decline in Turnover ...................................................................................................... 9 Increased illegal betting activity .................................................................................... 9 Commercial Appeal .................................................................................................... 10 Global Market ............................................................................................................. 10

B - INCREASE TURNOVER TAX TO 1.5% ............................................................................ 10 High Turnover business .............................................................................................. 10 Global Market ............................................................................................................. 12

COST TO EXCHEQUER FOR EVERY SHOP THAT CLOSES: ..................................................... 12 BETTING DUTY IMPLICATIONS ...................................................................................... 13

Total Profit made by the retail betting industry in Ireland ........................................... 13 Payments to Horse Racing in Ireland from Irish Betting shops per year .................... 14 Payments to Horse Racing in Ireland from UK & Irish betting shops per year ........... 14

HORSE RACING IN IRELAND .......................................................................................... 14 CONCLUSIONS ................................................................................................................. 15

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Executive Summary

• Retail betting is a major employer in Ireland with over 8000 direct jobs

• Taxation contribution by the sector to the exchequer is significant

• Taxation, antiquated legislation and recessionary factors cause arduous trading

conditions for Independent bookmakers

• Proposed taxation changes are unworkable and would cause massive closures

job losses and significant reduction in exchequer funding

• Racing Pictures and Data costs have soared in last 8 years, with much of the

increased reveue going to Racing

• Retail betting contribution to Irish racing far outweighs the revenue generated

• All relevant sectors should contribute fairly to Racing

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Retail betting overview The retail bookmaker sector is comprised of approximately 953 shops, with several head office locations, and employs over 8000 people. In addition to the usual income tax, profits tax, employment taxes and commercial rates the bookmaker sector carries a 1% on turnover betting duty. This 1% duty takes no account of profitability and does not apply to any form of betting/gambling other than bets made in a bookmakers shop. Online betting companies are to be taxed from August 1st, but there are still many operators in the space which do not pay this additional duty such as Spread betting, Tote, Lotteries, Gaming and others. Betting tax contravenes the principle underlying a fair progressive taxation system; “the more you make the more you pay”. Irish betting tax takes no account of profits or losses, and is forcing independent bookmakers out of business. There are three large chains in Ireland, leaving about 330 either standalone or very small group operations. Independent bookmakers, many of whom are in business for over 30 years, are a sector of the industry that has been abandoned. Any business in Ireland today, that is employing people and contributing to the exchequer should be protected and encouraged. Six jobs provided by an independent bookmaker in a betting shop in Carrigaline are as important as six jobs provided by Google in Dublin. Some retail operators have an online presence, but the majority of Independents do not. Unlike online operators, retail betting shops provide employment in most villages and towns across the country, contributing significantly to the local and national economy by way of taxes, rates, local products and services etc. Betting shops provide a well regulated, enjoyable leisure environment for adults, along with contributing significantly to the exchequer. The bookmaker sector has been adversely affected by the weak economic situation, high fixed costs, antiquated legislation, discriminatory betting duty and the growth of internet betting/gambling. Margins in the sector have tightened since the economic collapse and surge in online and mobile availability and the economic viability of many operations is in doubt. There have been over 400 closures since 2008, most of these being small Independent operators. However, as recently publicised even large International operators like Ladbrokes, are unable to trade in Ireland under the current cost base, and have entered Examinership.

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Sector Employment The Irish retail betting sector is a major employer for the Irish economy. Jobs are spread across Ireland, and are provided in most towns and villages. There are over 8,000 full-time or part-time jobs, which is equivalent to over 0.3% of total employment in the economy, and 0.6% of total private service sector employment.

Turnover levels The level of turnover in Irish betting shops has dropped dramatically from €3.4Billion in 2008 to €2.61Billion in 2014, as demonstrated in table 1.1 below;

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Shop Numbers The number of shops has also fallen dramatically. In 2008 there were 1365 betting shops across Ireland, and this has fallen to 953 in 2015. Each betting shop employs between five and six staff, resulting in over 2300 job losses in the sector since the recession began.

Taxation Contribution Ireland’s betting industry makes a very significant contribution to the economy at both a national and local level. Currently Irish betting shops pay a tax on all bets accepted in their shops. This tax is paid regardless of profitability, and the rate is 1% on every bet. Retail betting operators also pay the usual taxes such as PAYE/PRSI, USC, Corporation tax, and VAT. Unlike most businesses however, VAT is irrecoverable for betting operators, which causes their operating costs to be 23% higher than most businesses. Betting operators tend to occupy prime retail space, which attract the highest commercial rates.

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Average contribution to Exchequer As an illustrative example, the average licensed betting office makes the following contribution to the national exchequer and the local authority in which it is located:

Sample P&L Turnover €2,000,000 Gross Profit (@10%) €200,000 Estimated profit using Goodbody market research (profit after expenses) €5,000

Taxes Paid Betting Tax (@ 1%) €20,000 PAYE/PRSI €27,326 VAT €13,000 Rates €5,500 Corporation Tax €625

Total Taxation €66,451 Taxation as a % of profit 1329%

The National and Local Taxation Contribution: Moving from the local to the national picture, the total contribution of the betting sector to the national and local economy is estimated as follows:

Employment 8,000 jobs Betting Tax (@ 1%) €26,100,000 PAYE/PRSI €43,720,000 VAT €12,325,000 Rates €5,214,000 Corporation Tax €2,700,000 Total Taxation €90,059,000

“Apart from the direct contribution made by the betting industry to the Irish economy in terms of employment, taxes paid by employees, taxation paid by the industry itself, VAT and betting tax collected, commercial rates, and the income multiplier effect, the indigenous and regionally dispersed nature of the industry is very significant.”

Jim Power, Economist (2008)

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Payments for Irish Racing Media Betting shops also pay vast amounts of money for Irish racing pictures and data. It is estimated that each shop in Ireland and the UK pay’s approximately €3,000 each for Irish racing pictures, resulting in c€30million per year in media payments to Horse Racing Ireland and the race tracks. Racing’s income model is increasingly moving to a commercial basis via its increasing charges for media rights, despite the fact that bookmakers’ revenue from racing is in steep decline. Therefore relevant governing bodies should not expect exchequer or bookmaker support to continue even at its current level. Media costs for betting shops have increased by 33.5% since the recession began, in comparison to shop turnover which has nose-dived. Most of this increase is due to the increasing rights paid directly to Racing.

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Taxation Models proposed by others

A - Taxation on Consumer There have been suggestions made that betting shop customers should pay a betting tax from their winnings. The reason the tax was removed from the customer in the first place was because of the availability of alternative tax free betting opportunities. Should this tax be reintroduced it would have a severe negative impact on jobs and taxation received by the exchequer. There are many negative consequences of such a move and they include;

Decline in Turnover With a charge on the customer, there is the direct effect that the recycling of winnings will have on the number of bets and turnover. A typical betting customer will tend to start with an amount of money and then reinvest winnings to place further bets. If winnings are reduced or a tax to place the bet is incurred, the amount available for further bets is reduced. Tony Foley, Chief Economist with Dublin City University, calculated that a 2% tax on customer winnings, could reduce the turnover by up to 17%. Please visit site to read this paper.

This single change could wipe out the majority of betting shops in Ireland, causing thousands of job losses.

Increased illegal betting activity A tax on customers in a regulated environment will drive customers to avail of a cheaper alternative in an unregulated or illegal environment. Unlicensed operators can conduct their business in the corner of a pub, in an internet café, private members club or any unlicensed premises. The betting industry has spent many years reducing the incidence of illegal gambling, and any tax on a customer will provide a lifeline for illegal operators. This will also cause severe difficulties in complying with stringent AML requirements as demanded by the 4th Anti Money Laundering directive from the EU.

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Commercial Appeal With the imposition of a tax on customer, the betting product will become less attractive, meaning it is less value to the customer. Customers will seek lower cost alternatives, offering more value for their money, as for any normal product.

Global Market With the emergence of the internet and mobile technology, betting shops are now competing frantically with global operators. It may prove very difficult to police operators in the Carribbean or other countries, and unless they are all subject to the same tax, customers will flock to them to avoid paying the tax, and avail of their cheaper product.

B - Increase Turnover Tax to 1.5% It has also been suggested that Turnover tax at 1% is among the lowest rates in the world and needs to be increased to at least 1.5%. This statement fails to address the fact that the other countries operate a very different type of betting in a different type of market. Most offering computerised betting products, which have a wide range of products similar to the online offering, or offer a tote based product which has a built-in profit margin at whatever rate they choose, generally around 20%-26%, whereas Irish betting shops struggle to achieve 10%. Increasing the current Turnover tax rate will have severe negative effects on taxation and jobs for the following reasons;

High Turnover business Betting shops operate on a high turnover, high fixed costs, low margin business, which means that taxing the turnover is particularly inappropriate for this type of business model. A 1.5% Turnover tax would mean an effective tax rate of 100% for Paddy Power as demonstrated in recent Stockbroker note on Paddy Power PLC by Goodbody stockbrokers below.

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The situation is even more stark for Independent operators, who operate off a smaller margin and turnover. An average Independent shop would turnover €1,750,000 and struggle to make any money. In the example below provided by Goodbody stockbrokers, they have used a €2,000,000 shop. It clearly shows how an upward increase on the 1% Turnover tax would make vast majority of Independent betting shops loss making and unviable. A turnover tax takes no account of profitability of a shop, and falls due even in loss making units.

An entire Industry, employing over 8,000 people, which made c€10million in Profit after all taxes and expenses in 2014

would become loss making by -€3.05million if the turnover tax was to increase by .5%

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Global Market Emergence of online and mobile operators has resulted in Irish betting shops trading in an international market. Offshore operators can access Irish customers with ease, even inside a betting shop. As a result, bookmakers must compete with these operators daily, and on every market, which means their margin is dictated by foreign operators, and cannot be adjusted to reflect a higher taxation cost. Antiquated legislation prevents betting shops from competing with online operators and their vast range of products. Bookmakers continue to watch customers sit in their shop and use their mobile phones to avail of modern betting products with international operators, who have been trading betting tax free to date. Legislation prevents bookmakers from introducing many of these products, and therefore prevents bookmakers from having the ability to compete.

Cost to exchequer for every shop that closes: There are approx 5 – 6 staff in every betting shop. When a shop closes, apart from 5 - 6 peoples lives being devastated, there is a substantial loss to the exchequer. An average betting shop with a €2 million turnover, would cost the exchequer €161,607 per year if closed. Over €66,000 in direct taxes and €95,000 in unemployment benefit;

Taxes lost per Shop Closure Betting Tax (@ 1%) €20,000

PAYE/PRSI €27,326

VAT €13,000

Rates €5,500

Corporation Tax €625

Total Taxes Lost €66,451 Unemployment cost for staff €95,000 Total cost to exchequer per shop closure €161,451

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Betting duty implications It has been repeatedly stated that the betting industry tax is too low, and bookmakers should contribute more towards Horse Racing in Ireland. The facts behind the current figures demonstrate how erroneous these claims are;

Total Profit made by the retail betting industry in Ireland Estimated Net Profit from 950 Irish shops in 2014 was €10 - €12million

Paddy Power €15million (published accounts) BoyleSports € 3m to €5million (estimated) Ladbrokes -€ 5million (as announced by Examiner) Independents -€ 3million to -€ 5million (estimated) Total €10 - €12million

Profit made on Irish horse racing Irish betting shops derive approx. 12% of their overall turnover from Irish Racing. This would mean that c€1.2million profit is made from Irish Racing in Irish betting shops, but over €26 million is paid by them for it! Please see calculation below for breakdown of this figure.

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Payments to Horse Racing in Ireland from Irish Betting shops per year Betting Duty €21 million Picture Payments(excl UK shops) €3 million Sponsorship €2 million Total paid to Horse Racing in Ireland €26 million

Payments to Horse Racing in Ireland from UK & Irish betting shops per year Betting Duty €21 million Picture Payments(incl UK shops) €30 million Sponsorship €2 million Total paid to Horse Racing in Ireland €53 million

Horse Racing in Ireland Irish racing is an important and long established product in Irish betting shops. Customers that bet on Irish racing will regularly have a bet on something else while instore too. Betting shops also provide an important service for the racing industry, as they provide an inviting, comfortable and enjoyable ‘window’ for racing to showcase and market its product to a captive audience. Bookmakers are by far the largest financial contributor to Irish Racing. In the 2013 annual accounts published by Horse Racing Ireland, it summarises the income received as follows; Source: HRI Annual Report 2013, from 2011/2012 figures

Racing’s needs can and should be met from all income sources and not just increased betting tax on bookmakers.

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Included in the €75,657,000 totalled in table on previous page is;

• €21,000,000 in betting duty from Irish betting shops via the Horse and Greyhound Racing fund,

• €5,524,000 via Media Income for picture payments from Irish betting shops • c€2,000,000 in Sponsorship from bookmakers

A further • €25,000,000 going directly to racecourses for media payments from

bookmakers (which is not included in HRI accounts)

Conclusions The direct contribution made by the betting industry to the Irish economy in terms of employment, taxation paid by employees, VAT, betting tax, commercial rates, and the income multiplier effect, is very significant. By way of comparison, employment in the Irish betting industry is equivalent to almost 18% of the employment generated by the major retail bank groups in the Republic of Ireland. The Irish betting industry has a significantly greater coverage across Ireland than the banking industry. Betting offices are located in towns, cities and villages around the country and are a very important source of employment across Ireland. Land based operators should not be compared or treated the same as online operators due to the labour intensive nature of their business, high fixed cost base per unit, and the contributions made to local economies. Licensed betting offices typically occupy prime real estate locations. In a more difficult economic environment, with considerable office and retail space vacant, it would not be desirable to have these betting offices shutting down, cutting the contribution to local rates and adding to the excess supply of office and retail space available. The Irish betting sector has always been a keen supporter and promoter of Irish Racing via sponsorships, huge payments for media rights, and a turnover tax which far outweighs the profit made by most shops. However, demand for Irish Racing in betting shops is in decline, and now accounts for only 12% of total shop turnover. Accordingly, contribution for such a product must align itself with demand, and continuous increases in contribution from the state and betting sector must come to an end. Racing’s governing bodies should have an independent commercial review to maximise its income from all sources, or at least implement the commercial opportunities and efficiencies as highlighted in the Indecon report. The Irish Bookmakers Association requests that Ireland’s policy makers should now prioritise reforms to create a regulatory and fiscal environment that protects indigenous jobs, provides a level playing field for the betting industry and maximises the return to the exchequer from our sector.