

Brazil’s SPA releases note clarifying inclusion of rewards in gaming revenue calculations
Technical note clarifies aspects of the calculation base for Gross Gaming Revenue, especially regarding the inclusion of withdrawable or non-withdrawable rewards offered to bettors
Subjects
On May 8, 2025, the Brazilian Ministry of Finance’s Secretariat of Prizes and Betting (SPA) released SEI Technical Note No. 1,263/2025/MF. This document clarifies the rules on bonuses obtained by bettors and the criteria for including rewards in Gross Gaming Revenue (GGR) calculations.
In line with SEI Technical Note No. 229/2025/MF, the SPA has reiterated that withdrawable rewards offered to bettors should only be included in GGR calculations when they are effectively converted into bets. On the other hand, non-withdrawable rewards should be automatically included in the GGR calculations relevant to the month in which the reward is made available to the bettor, even if the amounts are not used for placing bets.
According to the SPA, non-withdrawable rewards are solely intended for betting. In light of this, and in order to discourage the indiscriminate use of such rewards, they must be immediately included in the GGR calculations even if the bettor does not place bets based on the amounts received.
Furthermore, note that the reward must not be considered in GGR calculations again if the bettor uses the reward to place bets after the month it is made available. Betting operators that do so will be subject to penalties associated with double-counting the same amount in the GGR calculation base.
For more information on this subject, please contact Mattos Filho’s Entertainment and Tax practice areas.