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But the court said that point did not affect the validity of the by-law, adding that it saw no evidence of a tax that would choke businesses.
The judges highlighted the number of gaming halls in the city remained largely stable after the increase.
The court also dismissed the equal-treatment argument, noting that gaming machines are taxed by the municipality while casino taxation falls to Hesse.
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“These two markets have been growing and will continue to grow very nicely [for] online, Spain even more than Italy,” he commented.
“Cirsa has incredible knowledge of the market, the consumers in general, also of the business. You will see a company with a huge understanding of the market, of the consumers, with an incredible retail platform, which can be leveraged for online.
Cirsa also holds a presence in Italy, and Angelozzi was asked whether this could cause any regulatory discomfort or revenue attrition.
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Touch Sokhak, deputy spokesperson of the Ministry of Interior, emphasised that the operation seeks to prevent Cambodia from becoming “a safe haven or money-laundering base for technology-related criminals”.
However, the sustained enforcement drive has already taken a toll on the wider Cambodian economy. In May, the government lowered its 2026 GDP growth forecast as construction, real estate and consumer spending absorb the short-term impact of the crackdown.
Meanwhile, the CGMC has not disclosed when the integrity and quality framework will be finalised, leaving casino operators without concrete guidance on the new requirements.