Follow the tax money: Bet3000 versus Lottoland

A conservative internal Bet3000-linked tax compilation records €211,171,607.82 in German payments. Lilith Wittmann's Lottoland investigation points instead to disputed liabilities running into hundreds of millions. The figures are not equivalent, but the gap between a payment ledger and an unresolved tax controversy demands a clearer regulatory answer.

The most concrete number in the latest Bet3000 file is not a licence date, a LUGAS error count or a regulatory deadline. It is €211,171,607.82. That is the total shown in a conservative internal compilation of German tax payments linked to the Bet3000 business, covering IBA Entertainment Limited and legacy Springer Sport entries from July 2012 through tax periods in early 2025. The spreadsheet does not read like a publicity document. It contains monthly liabilities, split transfers, corrections, late-payment fees and even a tax repayment credited back into the reconciliation.

The number becomes politically uncomfortable when placed beside the Lottoland investigation published by journalist and security researcher Lilith Wittmann on 21 July 2026. Her analysis of internal Lottoland material, company accounts and records obtained during her wider investigation into the Malta Gaming Authority argues that German lottery tax and money intended for social purposes may have gone unpaid in amounts running into hundreds of millions of euros. Lottoland rejects that analysis, says the material is incomplete and misleading and maintains that all taxes legally required in Germany were paid. Those competing positions have not been resolved by a public tax assessment.

This is not an apples-to-apples comparison and it would be dishonest to present it as one. The Bet3000-linked figure is an internal record of transfers booked as payments to the German tax authority, while Wittmann's Lottoland figures are calculations of disputed liabilities derived from turnover, stakes and assumptions about the German share of the business. The companies, products, tax categories and periods are different. One side therefore offers a payment trail that still requires independent confirmation, while the other presents allegations that still require a complete official answer.

The regulatory relevance comes from the GGL‘s own words. In July 2022, when the authority explained how it intended to attack illegal online gambling, it described referrals to tax offices as one of its most effective tools and said that tax debts could make the chance of a future licence approach zero. The law also permits information to move between tax authorities and gambling regulators for supervisory and tax purposes. Germany cannot make tax compliance central to licensing and enforcement, then leave the public unable to understand whether the same seriousness is applied when the underlying records point in radically different directions.

What the Bet3000-linked workbook actually records

Malta Media reviewed two internal spreadsheet files relating to German gaming-tax transactions. The smaller reconciliation workbook provides the cleaner and more conservative figure. Its summary records €130,285,265.71 for July 2012 to December 2020, €36,710,617.35 for July 2021 to December 2022, €40,377,994.03 for January 2023 to December 2024 and €3,797,730.73 in the early-2025 payment section. Added together, the workbook gives €211,171,607.82.

The historic section includes entries attributed to IBA Entertainment and legacy Springer Sport activity. That is why the figure should be described as Bet3000-linked rather than as an IBA-only total. The summary also does not separately identify January to June 2021, so it should not be presented as a perfect month-by-month history without gaps. The most defensible description is that the records show at least €211.17 million in recorded German tax payments across the periods included in the conservative compilation.

The workbook is not an official certificate from the Finanzamt. Malta Media has not seen tax-clearance letters, bank confirmations for every transfer or a complete assessment file from the competent authority. An internal accounting record can be genuine and still contain classification errors, timing differences or incomplete historic data. It is stronger evidence than a corporate assertion, but it is not the final word that only the tax authority can provide.

Period shown in the conservative workbook	Recorded payments
July 2012 to December 2020	€130,285,265.71
July 2021 to December 2022	€36,710,617.35
January 2023 to December 2024	€40,377,994.03
Early-2025 payment section	€3,797,730.73
Conservative compiled total	€211,171,607.82

Source: internal Bet3000-linked reconciliation workbook reviewed by Malta Media. The amounts are recorded payments in the compilation and have not been independently certified by the German tax authority.

The records look like transactions, not a press release

The detail in the workbook is important. For 2023 and 2024, the entries repeatedly identify payments to Finanzamt Frankfurt for individual gaming-tax months. Larger liabilities were sometimes settled in more than one transfer, including separate payments of €100,000 and €2,227,361.03 for October 2023, two transfers for August 2024 and staged payments for several later months. The accounting pattern is the opposite of a single rounded number created for an argument after the event.

The reconciliations also preserve discrepancies instead of hiding them. The July 2021 to December 2022 sheet shows €36,655,250.10 as adjusted tax due and €36,710,617.35 as paid, leaving a difference of about €55,367.25. The 2023 and 2024 section records €40,377,143.69 in liability entries and €40,377,994.03 in payments, a difference of €850.34. A July 2022 repayment of €1,111,249.13 appears in the wider reconciliation, which shows that credits and corrections were netted rather than simply ignored.

The early-2025 section is less tidy and should be described with care. It contains journal liabilities totalling €4,630,942.39 and payment entries totalling €3,797,730.73, alongside later settlement dates and late-payment fees. That difference does not establish an unpaid final liability because the section mixes tax periods, booking dates and transfers made after the month concerned. It does establish that the workbook is a working reconciliation rather than a polished statement claiming every liability was settled on the day it arose.

A second workbook points higher, but Malta Media is not using the larger number

The expanded file contains a far larger raw Sage transaction export and a separate summary reaching €228,279,209.37. It attributes €208,239,628.56 to IBA Entertainment and €20,039,580.81 to Springer Sport. That file may ultimately prove more complete, but its summary heading says the total runs only to April 2025 while the underlying transaction data includes later 2025 entries. The period label and the underlying dates therefore do not align cleanly enough for the higher number to be used as the headline figure.

The cautious approach is to publish the lower total that can be reconstructed from the internally coherent summary and to explain the existence of the larger working file. Choosing €211.17 million instead of €228.28 million is not a concession to Bet3000 or an attempt to minimise its tax contribution. It is basic evidential discipline. An investigation should not use the largest number available simply because it makes the headline stronger.

Tax paid does not erase the Bet3000 case

A substantial tax record does not answer the compliance findings that led the GGL to revoke IBA Entertainment's permission in July 2024. Tax payment does not cure failures in the activity file, the provider-wide limit system, technical supervision or any other licence condition. A company can pay large amounts to the state and still breach gambling rules. Bet3000 is not entitled to regulatory immunity because its historic tax contribution was significant.

The tax record does, however, correct a misleading picture that can arise when revocation becomes the entire public identity of a company. Bet3000 was not an operator sitting outside Germany's fiscal system while extracting value from German players without leaving a trace. The internal records describe years of recurring transfers to the German tax authority, often in seven-figure monthly amounts. That history belongs in any fair assessment of the relationship between the business and the German state.

It also changes the proportionality debate. When the state removes an operator that has paid more than €211 million in recorded gambling taxes, the decision does not only affect shareholders and franchisees. It also removes an established tax stream and redistributes customer demand across the remaining licensed and unlicensed market. That is not a reason to overlook breaches, but it is a reason to expect the regulator to explain why remediation, suspension or a shorter licence could not protect the public interest.

What Lilith Wittmann alleges about Lottoland

Wittmann's Lottoland investigation starts from a very different evidence base. She identifies European Lotto and Betting Limited, a Maltese company, as the entity that handled much of the relevant German and Austrian operation from 2019. Company accounts cited in her report show lottery-business revenues of €139,859,475 in 2019, €224,723,755 in 2020, €259,471,419 in 2021, €301,537,407 in 2022 and €311,952,464 in 2023. Across those five years, the reported total is €1,237,544,520.

An internal management profit-and-loss document for the first half of 2020 allegedly attributed about 95% of income to Germany. Wittmann says later documents no longer provide the same country breakdown, so she applies a lower assumption of 80% German business for her calculations. On that basis, she estimates around €165 million in German lottery tax and approximately €227 million that would otherwise have supported social purposes. Those numbers are her analysis of the records, not assessments issued by a German tax office.

She separately examines almost €6.4 billion in reported stakes across lottery betting, slots and sports betting between 2019 and 2023. Applying an 80% German share and the relevant 5% or 5.3% gambling-tax rates, she estimates a tax amount of roughly €255 million. She then compares that with approximately €35 million in gambling tax shown as paid in the accounts she reviewed. Malta Media has not added these figures into one single liability because the product categories, bases and possible overlaps require a complete tax analysis rather than headline arithmetic.

Lottoland disputes the central premise. In the response reported by Wittmann, the company says it has always paid all taxes legally required in Germany and describes the data as incomplete, taken out of context and misleading in important respects. It also disputes the suggestion that more than 90% of ELBL turnover came from Germany. That denial is substantive and must sit beside every reference to the alleged liability until the competent authorities establish the position from complete records.

The numbers are not a mirror image

The temptation is to place €211 million on one side and hundreds of millions in alleged Lottoland liabilities on the other, then declare a double standard. That would be rhetorically easy and journalistically weak. Bet3000's figure is a cash-payment compilation. Wittmann's figures are estimates of what may have been due. The first question is whether the payment records are complete and genuine, while the second is whether the revenue attribution, taxable base and legal interpretation used in the estimates are correct.

The tax categories also differ. Bet3000's workbook concerns gaming-tax entries associated with sports betting, for which the current federal rate is 5.3% of the statutory assessment base. Lottoland's secondary-lottery activity raises lottery tax under a different part of the Rennwett- und Lotteriegesetz. The statutory lottery-tax rate is 20% of the net-of-tax base, which is why public discussions often describe the effective share of the gross ticket price as roughly one sixth. Money allocated to social purposes is a separate policy and distribution question rather than simply another federal tax line.

Different products can create different liabilities without creating different standards. What should remain consistent is the seriousness with which authorities establish the facts. A payment ledger should be checked against tax accounts, bank records and assessments. A disputed liability model should be tested against full turnover data, customer location evidence, product classification and actual declarations. The regulator's credibility depends less on which side produces the larger number than on whether both sides are subjected to a method the public can recognise as equally rigorous.

German law does not make illegal gambling tax-free

One of the most important legal points in Wittmann's report is also the least dependent on her assumptions. German tax law does not say that an unauthorised gambling offer escapes tax because the gambling activity itself is illegal. Section 26 of the Rennwett- und Lotteriegesetz brings public lotteries within the tax where the organiser is established in Germany or where a player takes the acts required to conclude the contract in Germany with a foreign organiser. The same provision expressly includes secondary lotteries.

Section 29 sets the lottery-tax rate at 20% of the assessment base defined in section 27. Sports betting is governed separately, with section 18 setting the current rate at 5.3% of the section 17 base. The legal categories may be disputed in individual structures, but the basic principle is clear: operating from abroad does not by itself remove the German tax nexus when German players conclude the relevant gambling contracts from Germany.

That principle is essential to enforcement because otherwise the tax system would reward the operator that stays outside the licensing regime. A licensed bookmaker would pay tax on German stakes while an illegal competitor could claim that illegality made the same market fiscally invisible. The statute is designed to prevent that result. The real dispute is therefore not whether illegal gambling can be taxed, but what activity occurred, which entity organised it, how much of it was German and what was actually declared and paid.

The GGL itself made tax compliance a licensing issue

The GGL removed any doubt about the regulatory importance of tax in its first months of national enforcement. In a July 2022 statement concerning illegal lottery betting and the Lottoland and Lottohelden brands, board member Ronald Benter described referrals to tax offices as one of the most effective instruments against illegal online gambling. He added that where tax debts exist, the probability of receiving a future permit approaches zero and that already granted concessions can also be revoked.

German law gives that position an information route. Section 61 of the Rennwett- und Lotteriegesetz permits tax authorities to disclose protected data to the gambling supervisory authority where needed for supervision or licensing. Section 62 requires gambling and licensing authorities to pass information to the tax authority where it can serve a tax procedure. Tax secrecy under section 30 of the Abgabenordnung limits what officials can publish, but it does not require the gambling regulator and tax authority to operate in separate rooms without sharing relevant knowledge.

That distinction matters when the GGL invokes confidentiality. The public is not entitled to see a company's tax returns or a confidential assessment file. It is still reasonable to ask whether allegations were referred, whether the competent authority reported a material tax problem for licensing purposes and whether historic liabilities were considered in a reliability assessment. A regulator can answer those process questions without disclosing protected figures or prejudging a tax investigation.

The separate German Lottoland licence does not settle the historic question

Lottoland Deutschland GmbH is a separate legal entity and currently appears in the German regulatory system as a licensed commercial lottery intermediary. The international offer associated with lottoland.com is not covered by that permission and the GGL's current El Gordo guidance continues to describe the international secondary-lottery offer as illegal for German customers. Those two facts can coexist because licences attach to specific companies, products and domains.

It would be legally wrong to transfer any historic tax liability of ELBL or another international company automatically onto Lottoland Deutschland GmbH. Corporate separation matters and a German licence does not make the applicant responsible for every claim involving a different entity with a related brand. The licensing question is narrower: what did the GGL know about the wider transformation, the reported customer and value transfers and any option arrangement when it assessed the German company's independence and reliability?

Wittmann reports that a legalisation plan had been presented to German authorities as early as 2020, with a separate German company and a later transformation of the German-facing business. She also reports a one-euro call option favouring the international group and a licence condition addressing a possible later acquisition. Those reports do not establish current control or transfer historic liabilities. They do explain why the tax history of the wider commercial operation cannot simply be treated as irrelevant background when valuable customers, brand rights or business opportunities may form part of a transition into the licensed market.

One operator has produced a ledger. The other needs a verified answer

The Bet3000-linked workbook gives authorities something concrete to test. They can compare every monthly line with the relevant tax account, the original bank transfer, the filed return and the final assessment. If the €211.17 million total is overstated, incomplete or misclassified, that can be established. If it is accurate, the same exercise can turn an internal company record into an independently verified tax history.

The Lottoland controversy requires the same documentary discipline in the opposite direction. The tax authority can test the ELBL accounts, country allocation, customer location data, stakes, product classification and payments. It can determine whether Wittmann's assumptions are too high, too low or based on the wrong taxable base. It can also establish whether the approximately €35 million shown in the accounts represented the correct German obligation or only part of it.

Neither exercise should be conducted through public-relations statements. Bet3000 should not expect its own workbook to be accepted without verification and Lottoland should not expect a general assurance that all legally required taxes were paid to close a dispute built on specific revenue and stake figures. The answer on both sides is documentary proof tested by the authority with legal access to the complete record.

The €211 million record changes the fairness debate

The Bet3000 figure does not prove that the GGL's 2024 revocation was unlawful. It does show why the company should not be reduced to a technical failure narrative with no wider public contribution. More than €211 million in recorded tax payments is material by any standard, particularly for a business whose licence removal also affected a stationary network, franchisees and employees. It means the state had a long fiscal relationship with the operator before deciding that its technical and organisational failures made it unreliable.

That makes the contrast with unresolved illegal-market tax questions more important. A regulator can act quickly against a licensed company because the company is identified, supervised and dependent on permission. An international business can force authorities to reconstruct turnover, trace entities and pursue information across borders before any final tax position becomes visible. The asymmetry is understandable, but it becomes corrosive when the cooperative operator's failures are public and final while the harder operator's alleged liabilities remain an unresolved public argument for years.

Germany should not respond by weakening supervision of Bet3000 or any other licensee. It should respond by making tax enforcement against persistent illegal activity just as outcome-focused as technical enforcement against the licensed market. The state cannot build a credible channelisation policy if payment, licensing and tax obligations are most visible only for the companies already easiest to control.

What the authorities should be able to say

The GGL does not need to publish confidential tax returns to improve the position. It can say whether the Wittmann material was referred to the competent tax authority, whether a response relevant to gambling supervision was received and whether any unresolved tax risk affected the licensing assessment of Lottoland Deutschland. It can explain, at a methodological level, how tax history and corporate separation are tested when an international illegal-market business is expected to transfer customers or value into a licensed German structure.

The competent tax authority can remain within the limits of tax secrecy while confirming whether the matters raised are being examined, where the law permits such confirmation. IBA and Bet3000 can support verification by providing redacted tax account statements, assessment notices or an auditor's reconciliation tied to the workbook. Lottoland and ELBL can answer the same challenge by publishing a category-by-category reconciliation of German stakes, lottery turnover, declared bases and payments for 2019 to 2023, supported by independent assurance.

None of those steps requires a public trial by spreadsheet. They require each side to move from assertion to evidence. The public discussion is currently distorted because one internal ledger can be examined line by line while the Lottoland dispute is dominated by competing global statements about what was legally due. A regulator that made tax debt central to market access should want that evidential imbalance resolved.

Our Final Thoughts and Conclusion

Following the tax money does not produce a simple verdict, but it produces a much clearer map of the problem. The conservative Bet3000-linked workbook records €211,171,607.82 in German tax payments across the periods it covers. It contains the kind of operational detail that can be tested against official records, while also carrying limitations that prevent Malta Media from treating it as a tax-clearance certificate. A separate expanded file points to a higher amount, but its inconsistent period labels are precisely why the lower figure is the responsible one to publish.

The Lottoland side remains fundamentally different. Lilith Wittmann has presented a detailed and serious calculation suggesting that lottery tax, gambling tax and money intended for social purposes may have been missing in amounts measured in hundreds of millions. Lottoland disputes the data, assumptions and conclusions and says all legally required German taxes were paid. Until the competent authorities test the full records, those figures remain allegations rather than established debts.

The regulatory question is no longer whether tax belongs in gambling supervision. The GGL answered that itself in 2022 when it said tax referrals were among its most effective enforcement tools and that tax debts could destroy the prospect of a licence. German law gives tax and gambling authorities the ability to share relevant information. Tax secrecy protects the details, but it cannot become a convenient explanation for public silence about whether the system worked.

Bet3000's tax ledger is not a pardon and Lottoland's disputed liability is not a conviction. The fair conclusion is harder and more useful: one operator has produced a record showing more than €211 million in payments, while another major regulatory story still contains unanswered allegations of extraordinary historic liabilities. Germany does not need matching punishments for different businesses. It needs a transparent method that can show the same determination to verify the money wherever the trail leads.

FAQs

How much does the Bet3000-linked tax workbook record in German payments?
The conservative internal compilation reviewed by Malta Media records €211,171,607.82 in German tax payments across the periods covered by the workbook. The total includes entries linked to IBA Entertainment Limited and legacy Springer Sport activity.

Does the €211 million figure prove that all Bet3000 taxes were fully settled?
No. The workbook is an internal accounting record rather than an official tax-clearance certificate. Malta Media has not seen complete tax assessments, bank confirmations for every transfer or official clearance documents from the competent German tax authority.

Why is the Bet3000 tax figure described as conservative?
A second, expanded workbook contains a higher summary figure of approximately €228.28 million, but inconsistencies between its stated period and underlying transaction dates make the lower €211.17 million total the more defensible figure.

Does Bet3000's tax history invalidate the GGL's regulatory action?
No. A substantial tax record does not erase compliance failures or automatically make a licence revocation unlawful. Tax compliance and gambling-licence compliance are separate issues, although the size of the recorded tax contribution adds another dimension to questions of proportionality.

Why does the article compare Bet3000 with Lottoland?
The comparison highlights two very different evidential situations. Bet3000 has an internal record showing more than €211 million in payments, while allegations concerning Lottoland involve disputed calculations of potential historic tax liabilities rather than an established official assessment.

What tax allegations have been made regarding Lottoland?
Journalist and security researcher Lilith Wittmann has argued that German lottery tax, gambling tax and money intended for social purposes may have gone unpaid in amounts reaching hundreds of millions of euros. Lottoland rejects those conclusions and says all taxes legally required in Germany were paid.

Are the Bet3000 and Lottoland figures directly comparable?
No. Bet3000's figure represents recorded payments, while the figures concerning Lottoland are estimates of disputed liabilities based on revenue, stakes and assumptions about German business. The relevant products, tax categories, periods and evidence bases also differ.

Can unauthorised gambling activity still be taxed in Germany?
Yes. The article explains that German tax law does not automatically exempt gambling from taxation simply because an offer is unauthorised. The Rennwett- und Lotteriegesetz contains provisions covering lotteries, secondary lotteries and sports betting where the relevant German tax nexus exists.

Why is tax compliance relevant to GGL licensing decisions?
The GGL has itself treated tax compliance as an important enforcement and licensing issue. The article notes that the authority stated in 2022 that referrals to tax offices were an effective enforcement tool and that tax debts could significantly affect the prospect of receiving or retaining a gambling licence.

What regulatory question does the Bet3000 tax record ultimately raise?
The central question is whether German authorities apply equally rigorous methods when verifying tax compliance across licensed and allegedly illegal-market operators. The article argues that payment ledgers and disputed liability models should both be tested against complete documentary evidence rather than accepted through corporate or regulatory assertions alone.