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Monthly Archives: April 2020

Financial services lobbyists request EU delay anti-avoidance measures

23rd April 2020 by Alex Dunnagan

A consortium of financial services lobbyists has written to the European Commission calling for a delay to the implementation of anti-avoidance measures due to be rolled out on 01 July.1 As first reported in Law360,2 the letter – also sent to the OECD and to Finance Ministers in the EU and the UK – claims that due to the unfolding Covid-19 pandemic, businesses are unable to devote enough time to complete their preparations for the reporting required.

In a separate letter seen by TaxWatch, the European Banking Federation (EBF) requested a three-month postponement of the requirement to provide information on customer bank accounts to tax authorities.

The sixth version of the EU Directive on administrative cooperation, or DAC6, aims to provide the tax authorities of EU Member States and the UK with additional information to assist in closing tax loopholes. DAC6 requires EU and UK intermediaries to file information on “reportable cross-border arrangements” to their home tax authorities. One test of whether an arrangement must be reported is if its “main benefit” is to gain a tax advantage. The definition of what an intermediary includes is broad, and includes any individual or company who sells cross-border tax arrangements, i.e. accountants, tax advisers, lawyers, banks.34

The implementation of DAC6 has already been challenging. The way EU directives work is that they set out an objective, and give EU states a choice of how to achieve it.5 DAC6 was passed by the European Commission in June 2018, though individual member states were slow to implement the Directive as domestic legislation, with almost half of the EU member states missing the 31 December 2019 deadline to implement DAC6. However, should a member state fail to implement an EU Directive as domestic legislation, the Directive itself acts as a backstop – effectively meaning that regardless of action taken at a national level, businesses should have been aware that DAC6 would be coming into effect.

This is reflected by Big Four accountancy firms that have been recommending for over a year that affected institutions should begin their implementation efforts, even before member states have transported the EU Directive into local law.67 Despite the two years that relevant parties have had to prepare for DAC6, lobbyists are suggesting that as some people are off work due to having the coronavirus illness, or have childcare duties as a result of school closures, that the intermediaries affected by DAC6 will be unable to comply with the requirements.

The request asks for a postponement of reporting deadlines until 2021, with a review at the end of September 2020 to see if a further extension is required.

The EBF, one of the groups lobbying for a delay of DAC6, wrote separately last week to both the European Commission and the OECD, requesting a three month postponement of the deadline for information exchange under the Common Reporting Standard (CRS). This requirement, based on the US Foreign Account Tax Compliance Act, is a global initiative to combat tax evasion, and was implemented in the UK on 01 October 2018. The CRS is used to determine the personal financial information that must be shared regarding assets, income, and taxable amounts across international borders, and is reported annually. The added transparency on a global basis provided by the CRS should allow for enhanced enforcement actions, not only against tax evaders, but also against those involved in money laundering and terrorist financing.8

Again, the reason given was that workforces are struggling with technology constraints due to working from home. This request is more controversial, given the fact that the CRS has been in place for several years, and is global in its scope. The other nine signatories of the 20 April request have not put their names to this letter.

This is not the first time that interest groups have sought to use the coronavirus to delay tax measures. Earlier this month we reported on how TechUK, the industry group that represents Facebook and Google amongst others, had asked the UK government for a delay to the start of the Digital Services Tax, saying that companies will be unable to cope with the burden of extra compliance during the crisis. A similar campaign is being waged to defer the Indian digital tax.9

The coronavirus pandemic is undoubtedly having an effect on the ability of companies to conduct business. However, given the huge amount of resources required by governments fighting the impacts of the virus, is now really the time to delay measures designed to combat corporate tax avoidance, tax evasion, and money laundering?

The full letter requesting a delay to DAC6 can be found here – Request to European Commission to recommend/endorse the deferral of EU DAC6 reporting obligations

Photo by Calvin Hanson on Unsplash

1The associations who signed the letter, dated 20 April 2020, are ACC, AFME, AIMA, EACB, EBF, EFAMA, EFSA, ESBG, Insurance Europe and Invest Europe.

2EU Should Suspend New Anti-Avoidance Rules, Lobbyists Say, Law360, 21 April 2020, https://www.law360.com/financial-services-uk/articles/1265736/eu-should-suspend-new-anti-avoidance-rules-lobbyists-say?about=financial-services-uk

3Council Directive 2018/822/EU of 25 May 2018, https://ec.europa.eu/taxation_customs/sites/taxation/files/dac-6-council-directive-2018_en.pdf

4DAC6: EU Mandatory Disclosure Regime, Deloitte, https://www2.deloitte.com/uk/en/pages/tax/articles/dac6-eu-mandatory-disclosure-regime.html

5A good explainer of how EU Directives work has been produced by Full Fact, How the EU works: EU law and the UK, Full Fact, 11 March 2016, https://fullfact.org/europe/eu-law-and-uk/

6EU Mandatory Disclosure Requirements – Update, KPMG, 08 February 2019, https://home.kpmg/xx/en/home/insights/2019/02/etf-394-eu-mandatory-disclosure-requirements-update.html

7DAC6: The clock is ticking… Less than 1 year until go-live, Deloitte, 02 July 2019, https://blogs.deloitte.ch/tax/2019/07/dac6-the-clock-is-ticking.html

8The OECD common reporting standard (CRS): FATCA is going global, Gibson Dunn, 11 June 2015, https://www.gibsondunn.com/wp-content/uploads/documents/publications/Schmid-Grunert-OECD-common-reporting-standard-BLM-02.2015.pdf

9Tech giants such as Google, Facebook seek to defer Indian digital tax – sources, Reuters, 31 March 2020, https://uk.reuters.com/article/uk-india-tax-digital/tech-giants-such-as-google-facebook-seek-to-defer-indian-digital-tax-sources-idUKKBN21I1XY

The coronavirus is not an excuse for tech giants to cash in on taxpayer generosity

14th April 2020 by George Turner

Throughout the coronavirus crisis, technology companies have played an important role in efforts to combat the disease. Google has been using its data to monitor movements amongst the population and test the effectiveness of lockdown measures. Amazon has partnered with the government to deliver Covid-19 testing kits.

But will all of this work come at a price?

In the UK, TechUK, the industry group that represents Facebook and Google as well as many others has asked for the government to delay the start of the Digital Services Tax. The Times reports today that the argument being deployed by TechUK is that recent changes to the tax have widened the scope of the tax, causing an unexpected compliance burden that companies can not meet during the crisis. Tax experts consulted by the paper, as well as our own research, have found no such changes to the UK legislation.

The Digital Services Tax is a new tax that has been imposed on the revenues of social media companies, search engines and online market places – Facebook, Google, and Amazon. The tax, which came into effect just a few days ago, places a 2% charge on revenues generated by these companies from UK customers. Although it is a new tax, it is in effect an anti-avoidance measure designed to counter some of the aggressive tax avoidance schemes used by these companies. It only applies to companies with global revenues of more than £750m, meaning that only the very largest companies are caught by it. There is a generous £25m tax free allowance built into the scheme.

The UK is not the only country to implement such a tax. According to the US Tax Foundation, 14 countries in Europe have either implemented or proposed a Digital Services Tax at rates ranging from 2%-7.5%.

The proliferation of Digital Services Taxes is a direct result of the failure of the OECD to agree on a comprehensive solution to the problem of tax avoidance by large multinational tech companies. A failure that has resulted in governments losing billions of pounds a year in tax revenues. In the UK we estimate that just five companies manage to avoid taxes of £1bn a year by shifting profits offshore.

Looked at in this context, the UK’s Digital Services Tax is a relatively modest measure, with the government estimating that it will collect around £400m a year from around 30 companies. Staggeringly, this estimate includes a 30% allowance for companies putting in place measures to avoid paying the tax. These figures are speculative, and the Office for Budget Responsibility say they come with a high degree of uncertainty.

At TaxWatch, using information published by the Treasury setting out how the tax operates, combined with our research estimating the revenues that large tech companies derive from UK customers, we estimate that a delay to the Digital Services Tax would benefit Google to the tune of £187m and Facebook £39m.

If implementation was delayed it would offset a significant chunk of the total amount companies are giving to governments to fight the coronavirus. The bill for Google is almost as much as the total amount of free ad credits Google has offered to the World Health Organisation and over 100 government agencies around the world ($250m (£203m)) as part of their response to the Coronavirus. A survey of what some tech companies have offered as part of the effort to fight coronavirus is set out here – http://13.40.187.124/tech_company_covid_donations/ 

Unfortunately, TechUK’s lobbying efforts appear not to be just the actions of one overzealous industry group in the UK. There appears to be a concerted effort by tech companies to use the coronavirus as an excuse to loosen regulations in a number of countries.

Reuters recently reported that in India, industry lobbyists representing the same companies are co-ordinating a similar campaign to defer the Indian version of the digital services tax.

Back in the United States, the New York Times reports how a number of tech companies have used the coronavirus to lobby against a range of government policies from labour laws to privacy protections.

Lobbyists may have thought the coronavirus outbreak an opportunity to realise long standing campaign aims, but they may have underestimated the reputational damage their clients could suffer if they are seen to be exploiting the crisis. The Times of London today ran a lead article heavily critical of the move from TechUK.

Government support mechanisms are supposed to be in place to help businesses in distress. Given that large tech companies are set to do relatively well out of the crisis, perhaps now is not the time for them to be looking for a hand-out. It is certainly not the time for governments to get rid of policies designed to combat tax avoidance by the tech industry.

We asked TechUK for a comment, they did not respond.

This research has been featured in The Times and The Telegraph.

Photo by Markus Spiske on Unsplash

Tech companies and the response to Covid-19

9th April 2020 by George Turner

As governments around the world struggle to deal with the outbreak of Covid-19 our tech companies are keen to show that they are playing their part too. Over the last two weeks there have been a number of announcements from the world’s largest tech companies setting out what they intend to do to help people through the current crisis. In total, as of 8th April, we have counted that eight companies have donated a total of $1.2bn in cash and in kind to counter the impact of the coronavirus. They range from an $800m package announced by Google (over 50% of the total), to free use of software for coronavirus researchers from Nvidia.

But how generous are these donations? Firstly, it should be stressed that many tech giants are not experiencing the same dread economic consequences other industries are suffering. With many shops forced to close, the retailers that can are moving online which will benefit online advertising providers such as Google and Facebook. A massive shift to homeworking will surely benefit companies like Microsoft, and online marketplaces have seen large increases in traffic. Amazon announced last month it will hire 100,000 extra staff in the United States to handle the surge in demand caused by coronavirus.1

More importantly, these donations are peanuts compared to the amount of money these companies have squirrelled away in tax havens over the years, depriving governments of tax revenues.

Until late 2017, when the US instituted wide ranging tax reform, US headquartered companies accumulated vast amounts of cash in tax havens.

In the tax world, there is some debate about whether this cash represented profits made outside the US, in market jurisdictions such as the UK, or US profits. Our research, which has looked at detailed US corporate filings, shows that as far as the companies themselves are concerned, the profits accumulated in tax havens are non-US profits.2

These stockpiles of cash came from profits made by US companies on sales of their products around the world. Using a complex series of transactions, often involving royalty payments or internal financing structures, profits were eliminated in the countries where these sales were actually made and transferred offshore to countries like Bermuda with a 0% corporate tax rate. The cash could not be transferred onto the United States, because untaxed foreign profits returned to the US would need to be taxed at the US federal tax rate, which at the time was 35%.

All of this changed at the end of 2017 when the Trump administration slashed the US corporate tax rate and introduced a new tax on the offshore cash holdings, which encouraged companies to bring their cash back into the US.

Up until 2017, US stock market listed companies regularly reported the amount of cash they held offshore. We can use these figures to understand how the total amount of profit these companies shifted out of non-US market jurisdictions over time. The amounts are truly staggering.

By 2017, Apple had accumulated $246bn in cash offshore, which is equivalent to the GDP of many small countries. Microsoft had accumulated $142bn.

A study from the Institute on Taxation and Economic Policy found that between Microsoft, Apple, Alphabet, Facebook, Cisco Systems, Adobe, Intel and Nvidia, these companies held $571bn in offshore tax havens by 2017.3

Companies still continue to move profits offshore from their non-US markets, however, reporting has slightly changed. Rather than report the increases in cash held offshore, companies now report the US tax charge they incur on profits declared in tax havens under new US anti-avoidance rules. We recently found that Netflix was subject to a tax charge of $43m in 2018 due to the US Minimum Tax on Foreign Entities. We believe that this is likely to be the Global Intangible Low Tax Income (GILTI) provision of the 2017 Trump Tax Reform. As we reported at the time, the disclosure that $43m is subject to the minimum tax rate suggests that between $327.8m and $430 of non-US profit was shifted into tax havens by Netflix in 2018.4

All of this puts the recent generosity of the tech giants into some context.

Overall, we calculate that the amount of cash donated by these tech giants accounts for just 0.22% of the total amount of profits accumulated in tax havens by the end of 2017. If we exclude Google, which makes up more than 50% of the total covid donations figure, the amount given comprises just 0.09% of tax haven cash accumulated.

Perhaps health services around the world would be better served if tech companies simply paid their taxes in normal times, rather than relying on handouts in a crisis?

We contacted Microsoft5, Apple, Alphabet, Facebook, Cisco Systems, Adobe, Intel and Nvidia, however, the above organisations either did not respond or declined to comment.

Company ITEP Amount Held offshore (2017) Financial Donations Material Donations Explanation
Microsoft $142,000,000,000 $1,000,000 On 09 March, Microsoft announced they would donate $1 million to Puget Sound’s (region in Seattle) covid Response Fund.
Apple $246,000,000,000 $15,000,000 20,000,000 masks On 13 March, Apple announced that they had donated $15m to covid response efforts, and that they would match employee donations two-to-one. On 05 April, Apple announced that they had sourced 20m masks to donate for medical workers.
Alphabet $60,700,000,000 $800,000,000 On 27 March, Google announced an $800m donation towards covid response. This included, but is not limited to, $250m in ad grants to the World Health Organization and other government agencies, a $400m investment fund to support NGOs and financial institutions, $340m in Google Ads credits to Small Business Banking, and $20m in Google Cloud credits for academic institutions.
Facebook $2,870,000,000 $135,000,000 720,000 masks, Facebook has made several announcements, as recently as 30 March, of $100m to aid journalists, $25m towards developing a treatment for covid, $10m to the Centre for Disease Control, and 720,000 masks, with millions more to come.
Cisco $65,600,000,000 $225,000,000 On 22 March, Cisco announced $225m in donations, this includes $8m in cash, $210m in product, and $5m in grants to non-profits.
Adobe $4,200,000,000 $3,000,000 On 24 March, Adobe announced a $3m donation, including $1m to the Red Cross and Red Crescent Societies, $1m to the Silicon Valley Community Foundation, and a commitment of $1m to match and double employee donations.
Intel $46,400,000,000 $60,000,000 On 07 April, Intel announced $50m in a ‘pandemic response technology initiative’. Intel had previously announced $10m in donations towards supporting local communities.
Nvidia $3,130,000,000 $0 Free access to software for covid researchers. On 19 March, Nvidia announced covid researchers would be given a 90-day license to Parabricks, software that allows for analysis of genomes.

All donations correct as at 1700hrs BST 08 April 2020.

This research has been featured in Law360 and The Independent among others.

Photo by Mika Baumeister on Unsplash

1Amazon ramps hiring, opening 100,000 new roles to support people relying on Amazon’s service in this stressful time, The Amazon Blog, 16 March 2020, https://blog.aboutamazon.com/operations/amazon-opening-100000-new-roles?utm_source=social&utm_medium=tw&utm_term=amznnews&utm_content=COVID-19_hiring&linkId=84444004

2US effective tax rate over 4 times higher for tech companies, TaxWatch, 08 April 2020, http://13.40.187.124/us_tech_companies_worldwide_profits/

3Offshore Shell Games 2017, Institute on Taxation and Economic Policy, 17 October 2017, https://itep.org/wp-content/uploads/offshoreshellgames2017.pdf

4No Tax and Chill: Netflix’s Offshore Network, TaxWatch, 14 January 2020, http://13.40.187.124/reports/netflix_tax_avoidance/

5It is important to note that the Bill & Melinda Gates Foundation announced in February 2020 that they would spend up to $100m to improve the detection and treatment of Covid-19. To date, Bill Gates has donated $35.8bn worth of Microsoft stock to the foundation.

US effective tax rate over four times higher for tech companies

8th April 2020 by George Turner

A new study has shown that large technology companies have historically paid more than four times in tax on their US profits than on profits made in the rest of the world.

In our latest study, we looked at pre-tax profits reported by major multinational companies in the technology sector. Our study looked at Microsoft, Apple, Alphabet, Facebook, Cisco Systems, Adobe, Intel and Nvidia.

Under US stock market rules companies have to report the amount of their pre-tax profits that are made overseas and the taxes paid to foreign governments.

The study found that over the last five years technology companies have faced a tax rate of just 9.6% on profits generated outside of the US. By contrast, the same companies have seen a tax liability of 45% on profits generated in the United States.

Part of this significant gap is explained by the large, one-off tax bills faced by companies in the US to deal with historic tax abuse following tax reform in 2017. For example, in 2017 Apple faced a tax bill of 71% on its US profits. Google had an effective tax rate of 120% on its US profits. For some companies, these large charges also appear in 2018 and 2019 as new rules were issued by the IRS on how to account for the tax reforms brought in in 2017.

Average ETR 2015-2019 Microsoft Apple Alphabet Facebook Cisco Adobe Intel Nvidia Total
Foreign total tax rate 14.57% 8.21% 8.54% 5.21% 13.29% 6.94% 10.17% 3.12% 9.60%
Foreign income as % total 72.22% 67.31% 56.59% 66.06% 68.37% 67.14% 41.63% 57.74% 63.51%
US current tax rate 76.27% 68.44% 37.89% 52.42% 76.10% 32.22% 30.03% 10.06% 54.88%
US total tax rate 52.13% 48.08% 39.71% 48.36% 80.94% 20.81% 31.27% 3.75% 45.32%

However, pre-tax reform there were still very significant gaps between the rates these companies paid on US profits and on non-US profits.

In 2016, Google had a tax bill of just 7.6% outside the US and a rate of 28.7% on its US profits. In the same year, Facebook paid just 2.6% of non-US profits in tax, whereas in the US it faced a tax bill of 30.9% on US profits.

Recently, the gap appears to have closed, following significant tax cuts in the United States, which saw the headline rate of federal corporation tax fall from 35% to 21% in 2017. At the same time action by tax officials around the world has increased the focus on tax avoidance by multinational companies.

In 2019, the US based technology companies in our study had a total foreign tax bill of 13.6% on profits generated outside of the United States. The total US tax bill was 15.6% of US profits, or 25.4% on a current tax basis.

The worldwide average tax rate was 26% in 2019 when weighted by GDP.

The figures call into question the claims made by companies on why they pay so little tax outside of the United States. Frequently when challenged companies claim that the reason that non-US governments see relatively small tax payments in their jurisdiction is due to the fact that profits should be allocated to the United States – where the value of the product is created.

However, TaxWatch’s study shows that the majority of US tech companies state in their annual accounts that most of their profits are made outside of the United States. On average the companies in our study reported that 63.5% of their profits were generated outside of the United States.

In 2019, Facebook states that 79% of its pre-tax profit was made outside of the US. Adobe claimed that it made 86% of its profits outside of the United States, on which it paid a tax rate of just 7.2%. Nvidia, the maker of high end graphics cards made 50% of its profits outside of the US, on which it paid just 3.7% tax.

The study also showed significant differences between the corporation tax liabilities of different companies on their non-US profits.

Between 2015 and 2019 Microsoft paid 14.6% of its non-US profits in tax, whereas over the same period Nvidia paid just 3.12% of its foreign earnings in tax. Most companies achieved figures in the single digits.

To download a copy of this briefing in PDF – click here.

Photo by Allie Smith on Unsplash

bet365 and tax havens

1st April 2020 by Alex Dunnagan

Gambling is big business. The boss of bet365, Denise Coates, has been in the press recently for paying herself the staggering amount of £323m (£277m in salary plus £46m in dividends) last year, the equivalent of £1.3m per working day. £235bn in bets have been wagered through her company over the past five years, making it one of Britain’s largest bookies, generating some £684m in post-tax profits last year alone. With a net worth estimated at £9.3bn, Coates is thought to be one of the largest taxpayers in the UK.1 The Stoke based betting giant saw its post tax profits rise from £52m in 2009 to £685m in 2019.

However, scrutiny of the bookmaker’s accounts appear to show hundreds of millions of pounds a year in revenue generated in tax havens. In this article we delve into why this might be happening.

Almost every stock-market quoted gambling company gives a breakdown of its revenue. Family-owned bet365 doesn’t, stating in their accounts that “A geographical analysis of turnover has not been given, as in the opinion of the directors, such disclosure would be severely prejudicial to the interests of the group.” Analysts in 2018 estimated that three-quarters of revenue came from international sources.2

While the accounts are certainly not what you would call transparent, some idea of overseas earnings can be gleaned by looking at the company’s tax disclosures. Over the past five years, bet365 has seen a reduction of £176m in their corporation tax bill through what is listed as a “difference in tax of overseas subsidiaries”.

What this means is that bet365 has seen a 30% decrease in their tax bill versus what it would have been had all bets been processed in Britain, from £550m to £373m, thanks to profit generated in countries with a lower corporation tax rate than the UK. Though the amount of revenue generated in “overseas subsidiaries” is not listed in the publicly held accounts, in order to see a reduction of £176m the amount of overseas revenue must be in the billions.

Though bet365 has gambling licenses in 14 jurisdictions, the only ones with a lower corporation tax rate than the UK are Bulgaria, Cyprus, Ireland, and Gibraltar (combined population of 13m). bet365 would have to post pre-tax profits of £1.763bn in Gibraltar or Bulgaria over a five year period, jurisdictions with a corporation tax rate of 10%, in order to see a reduction of £176m in the company’s corporation tax bill. Should these profits be declared in Cyprus or Ireland, at a 12.5% corporate tax rate, the amount would have to be even higher. Either bet365 is making vast sums of money from these small jurisdictions, or another explanation is that they are using these jurisdictions to take bets from markets in which they have no license to operate.

There is much speculation online about bet365 operating in unregulated markets.34 Ralph Topping, a former chief executive at William Hill, says bet365 probably operates in many grey markets: “They have more risk appetite than puritanical companies.”5

A Guardian investigation from 2014 revealed that Chinese citizens had been arrested after gambling on bet365’s website, with the company frequently changing its Chinese web address in order to side-step regulation. The report goes on to claim that the bookmaker has a call centre in Stoke employing Chinese-speakers.6 Along with Fixed Odds Betting which is popular in the UK, bet365 also offer Asian Handicap betting, a type of gambling which is hugely popular in China. In response, bet365 said at the time:

“There is no legislation that expressly prohibits the supply of remote gambling services into China by operators who are based outside China. bet365 has no people, assets or infrastructure in China and does not engage any agents, aggregators or intermediaries, for any purpose, in China.

“In the view of bet365, and its lawyers, Chinese law does not extend to the provision of services into China by gambling operators and service providers who themselves have no nexus with the territory. Any allegation of illegality on the part of bet365 is therefore untrue.”

When we used a virtual private network to make it appear as though we were based in China, we found no difficulty in accessing bet365’s website.

In 2019, another British gaming company was unequivocally found to be operating in grey markets. The boss of GVC, responsible for betting giant Ladbrokes Coral and Foxy Bingo, apologised to the Nevada Gaming Commission for operating in Turkey, where gambling is restricted. Nevada regulators chastised the chief executive, calling him “lackadaisical” about GVC’s operations in Turkey.

Is bet365 operating in grey markets and moving hundreds of millions in profits through low-tax jurisdictions each year? Until bet365 is more transparent, we will never know.

We emailed bet365 to ask how much they generate in revenues from countries in which they don’t hold a license. The company has not responded to our request for comment.

This research was featured in The Times.

Photo by Chris Kendall on Unsplash

1 The Sunday Times Tax List 2020: meet Britain’s top 50 tax payers, 26 January 2020, 2019, available here; https://www.thetimes.co.uk/article/sunday-times-tax-list-2020-uk-taxpayers-nhs56k95d

2 bet365 stands out among rivals for more than pay, available here; https://www.ft.com/content/f40e1b44-ee60-11e8-89c8-d36339d835c0

3 Are Chinese punters big users of bet365? The firm still won’t say, 21 November 2018, https://www.theguardian.com/business/nils-pratley-on-finance/2018/nov/21/are-chinese-punters-big-users-of-bet365

4 UK gambling market comes under siege, 09 February 2020, https://www.ft.com/content/7eed86fc-4354-11ea-a43a-c4b328d9061c

5 bet365 stands out among rivals for more than pay, 22 November 2018, https://www.ft.com/content/f40e1b44-ee60-11e8-89c8-d36339d835c0

6 Revealed: how bet365 profits from Chinese punters who risk jail for gambling online, 03 October 2014, https://www.theguardian.com/society/2014/oct/03/bet365-profit-china-online-gambling


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