Gaming and Tax: Implications of M&A in the

Online Gaming Sector

In India.....................................................................................................................................1
Tax on winnings from online games...................................................................................2
Example of online gaming tax............................................................................................2
Basis of revenue collection and their changeability............................................................2
Comparison of current and proposed provisions on online gaming taxation.....................3
Brief:...................................................................................................................................6
I. Income Tax Act...............................................................................................................6
II. Equalization Levy...........................................................................................................7
III.Goods and Services Tax................................................................................................7
Foreign Direct Investment & Foreign Technology Collaborations in Gaming Industry.......8
Restrictions under Exchange Control Regulations.............................................................9
CURRENT TAX REGIME...................................................................................................9
PROPOSED TAX ON ONLINE GAMING.........................................................................10
Explosive Growth in Gaming is Powering Consolidation..................................................10
Analysis on the Impact of Tencent’s Acquisition of Riot Game......................................10
Why are companies buying into gaming?........................................................................11
Philippine Law......................................................................................................................11
Brief..................................................................................................................................16
Recent developments.......................................................................................................17
Application for tax treaty relief..........................................................................................18

In India

The online gaming industry in India has seen massive growth in the last ten years and is
expected to grow to $5 billion by 2025. The use of online gaming platforms, including card
gaming platforms, battlegrounds, sporting games, and quizzes, has resulted in offering real
money to its players.
Recently, the three bodies of the online gaming industry, namely, the E-Gaming Federation
(EGF), Federation of Indian Fantasy Sports (FIFS), and All India Gaming Federation (AIGF),
approached the Central Board of Direct Taxes (CBDT) to reconsider TDS regime changes
that have been effective from 1st April 2023.

Tax on winnings from online games

Presently, online gaming organisations charge 30% TDS on any winnings drawn by a user
above Rs.10,000 per transaction. The threshold of Rs.10,000 is still in place as of 1st April
2023, but now the taxation will depend on the annual income of the game user.

As per Finance Bill 2023, Sections 115BBJ and 194BA have been introduced to tax the user's
winnings on different gaming platforms.

● Under Section 115 BBJ, income tax would be charged on net winnings for the
previous fiscal year at a rate of 30%.
● Section 194BA mainly deals with TDS applicable on net winnings in the user's
gaming account at the end of the fiscal year. So, your net winnings from online
gaming platforms at the end of a fiscal year would be taxed at 30%.

The introduction of these sections suggests that in the coming days, TDS might also be
applicable on winnings below Rs.10,000.

Example of online gaming tax

Suppose you have paid Rs.1,000 as an entry fee to enter an online game and won Rs.40,000
from that. In such a case, the gaming firm will deduct your TDS on Rs. 39,000 (Rs. 40,000 -
Rs. 1,000) at 30%. Therefore, you will have to pay a tax of Rs. 11,700, which will get
deposited to the government and the remaining balance of Rs. 27,300 will be credited into
your account as your income from the win.

Basis of revenue collection and their chargeability

Some of the key sources of collecting revenue through online gaming and the applicability of
tax policy on them are discussed below:

● Contest entry amount (CEA) and gross gaming revenue

The government has proposed to levy a GST of 28% on the Gross Gaming Revenue (GGR)
of online gaming. As per the latest reports, 18% GST is charged simply on the CEA, but the
proposed rate is higher. According to the co-founder of Winzo Games, Saumya Singh
Rathore, the online gaming industry has the potential to become a big part of the Indian
economy, but enforcing 28% GST will untimely hold back this sector.

● Winning real money from online games

Different online gaming platforms such as Ludo Empire, Dream 11 and others provide a
chance to win real money for players. This income is taxable under the heading of 'Income
from other sources' under Sections 115BBJ and 194BA. A flat rate of 30% gets charged
without the inclusion of any threshold.

● Distribution during game tournaments

Winnings from different gaming tournaments are also charged under Sections 115BBJ and
194BA, as discussed above.

● Referral and joining bonuses

Any real money received as a joining or referral bonus is not taxable under the mentioned
sections. It is taxable on a net basis as per the slab rate applicable for individuals. No tax will
be payable if the earned income is below the maximum chargeable tax amount.

*Note: The taxable rate and applicable Sections may change per the proposed provisions of
online game taxations.

Comparison of current and proposed provisions on online gaming taxation

Particulars Current Provisions Proposed Provisions

Relevant provisions Taxation of winnings - Taxation of winnings -

1115BB 115BBJ

TDS - 194B TDS - 194BA

The minimum threshold for Rs.10,000 No provision of threshold

TDS

Effective dates Taxation of winnings - Up to Taxation of winnings - From

31st March 2023 1st April 2023

TDS - Up to 30th June 2023 TDS - From 1st July 2023

Rates of TDS Rates in force - 30%* Rates in force - 30%*

Timing of TDS Applicable during the
payment of winnings
Winning in kind Before releasing innings, the
payer must ensure that taxes
get paid on them.
Annually - Net winnings in
the user account will be
subject to prescribed
withholding tax at the end of
the financial year.
For withdrawals during the
year - Prescribed TDS will
be deducted from net
winnings at the time of
withdrawal and from the
remaining net winnings in
the user account at the end
of the financial year.
The online gaming platform
must ensure taxes get paid
on net winnings before
releasing them.
 Rate of income tax on such 30%* 30%*
winnings

Quantum of income to be No specific guidance is Income tax and TDS needs

taxed available on the taxation of to be computed on net
gross winnings in relation to winnings.
net winnings.

The calculation process for

net winnings will be
prescribed later.

*Plus applicable cess and surcharges

Brief:

The imposition of tax on online games is mandatory, irrespective of the amount you win. The
rapid growth of the online gaming industry is compelling the Indian government to bring
changes in tax rates, GST and applicable thresholds.

However, the changes proposed on GST rates can negatively impact the growth of the Indian
gaming sector, as a 28% GST levied can discourage players. But as this industry is rapidly
growing at both Indian and global levels, we can only hope that the Indian government will
take action to boost this sector and impose fair GST and tax rates on the participants.

Tax Gaming operatorsshould consider the impact of a number of tax implicationsthat could
apply to their India offerings. These largely fall within three buckets (as enumerated below):
I. Income Tax Act

Non-residents are typically taxable on income sourced in India. Consequently, non-residents

may be subject to tax in India if (a) they have more than 300,000 users in India, or (b) income
receipts more than INR 20 mn in a financial year. However,if treaty relief is available to the
overseas operator,taxes should not apply to such income without the creation of a permanent
establishment in India. § Gaming operators are also subject to a withholding obligations,
which requires the person responsible for paying winnings to the players to withhold taxes at
the rates in force (if the winnings are in excess of INR 10,000). Relief from the obligation to
withhold is offered in certain instances when the winnings are in kind (however, the deductor,
i.e., the operator, has further compliance obligations in such situations). The operation of this
provision has several nuances based on the specific facts and market practice differs with
respect to overseas operators in terms of compliance with this provision due to practical
difficulties.

II. Equalization Levy

In 2020, a new levy was introduced on overseas e-commerce operators that were receiving
consideration for e-commerce supply or services made/provided/facilitated by the e-
commerce operator to specified persons (including Indian residents). The equalization levy is
applicable at the rate of 2%, and overseas operators that are subject to the levy, are offered a
corresponding exemption from the application of income taxes under the ITA.

III. Goods and Services Tax

GSTis an indirect tax levied on the supply of goods orservices. With respectto the products
offered by gaming operators, a number of classification issues exist with respect to the
characterization of gaming products as an 'actionable claim' (included within the definition of
‘goods’ and taxable only when related to lottery, betting or gambling; and not otherwise), or
as a service, both of which imply separate rates and tax bases.

Another major issue faced by the operators in the gaming industry is with respect to the tax
rate and tax base determination. The classification as gambling (i.e., games of chance) vs
non-gambling (i.e., games of skill) is relevant here too as gambling is identified as a service
chargeable to tax at 28% (along with gambling-related actionable claims that are chargeable
to tax at the same rate), whereas non-gambling activities are chargeable to tax at the rate of
18%. Secondly, in the case of actionable claims, the entire stake value/bet value is deemed to
be the ‘good’ and thus, the entire bet value is chargeable to tax. However, for gambling and
non-gambling services, on the other hand, the tax base is restricted to the service fee charged
by the operator. Thus, classification as an actionable claim (i.e., a good), or as a service
continues to be a nuanced and important determination.

At the moment, there is also an ongoing deliberation at the level of the Group of Ministers, as
to whether (a) GST should be charged at the rate of 28% on both,skill gaming and chance
gaming, (b) whether the tax base should be the entire amount which a player deposits for a
game.This is currently undecided, and reports suggest that the ministers are seeking legal
opinions on the issue. Depending on the kind of products the operator is offering the
implications of the above may change based on the manner in which such products are
offered.

Foreign Direct Investment & Foreign Technology Collaborations in Gaming Industry

Under the Foreign Direct Investment Policy (“FDI Policy”) of India issued by the Ministry of
Commerce & Industry, Government of India, and as codified into law by the FEMA and the
Foreign Exchange Management (Non- Debt Instruments) Rules, 2019 (“Non-Debt Rules”),
Foreign Direct Investment (“FDI”) is prohibited in entities involved in:

● lottery, including government, private lottery, online lotteries, etc; and

● gambling and betting including casinos, etc.

The terms “lottery, gambling and betting” have not been defined under the FDI Policy.

Hence, one may rely on the statutes in pari materia, judgments (both domestic and foreign),
dictionaries, etc. for the meaning of these terms. In case of games of skill, an argument can be
made that it does not amount to ‘gambling and betting including casinos, etc,’ and
accordingly foreign direct investment may be permitted in such games.

Further, the Non-Debt Rules also prohibits foreign technology collaborations in any form
including licensing for franchise, trademark, brand name, management contract for lottery
business and gambling and betting activities. This prohibition should not apply in relation to
games of skill.

For violating the Non-Debt Rules, one may have to pay a penalty of up to thrice the sum
involved where such amount is quantifiable, or up to INR 2,00,000 (approx. USD 4000)
where the amount is not quantifiable, and where the contravention is a continuing one, further
penalty which may extend to INR 5,000 (approx. USD 100) for every day after the first day
during which the contravention continues. Several skill gaming companies have in fact
received foreign direct investment including Rummy and fantasy sports.

Restrictions under Exchange Control Regulations

Under the FEMA read with Foreign Exchange Management (Current Account Transaction)
Rules, 200046 (“Current Account Rules”), remittance of income from winnings from lottery,
racing/ riding or any other hobby is prohibited. Remittance for purchase of lottery tickets,
banned/proscribed magazines, football pools, and sweepstakes, etc. is also prohibited.

Remittance for the purpose of betting by a player or any remittance of prizesto any player in
foreign currency may potentially contravene these rules and incur penalties which may
extend up to three times the amount remitted.

The amendments that are related

⦁ Section 115BB: This section lays out the “tax on winnings from lotteries,

crossword puzzles, races including horse races, card games and other games of any sort or

gambling or betting of any form or nature whosoever”. The amendment basically says

that this provision doesn’t apply to online gaming—which is defined in Section 115BBJ

of the Act.

⦁ Section 115BBJ: This is a new section that’s supposed to be inserted into the

Income Tax Act. It basically lays out how the net winnings from online gaming should

be taxed. It also defines an online game as one that’s “offered on the internet and is

accessible by a user through a computer resource including any telecommunication

device.”
Both these amendments apply from April 1st, 2024 Because both will be applied to the
assessment year 2024-25—which is when taxes are collected for the financial year 2023-24.
The assessment year runs from April 1st, 2024 to March 31st, 2025. The financial year runs
from April 1st, 2023 to March 31st, 2024.

CURRENT TAX REGIME

The GST regime classifies and imposes various rates on goods and services; 28% being the
highest on a few items. Online Skilling games are at present taxed on the platform fee at 18%
and not on the price pool. The winnings from online games are taxable at 30% per the Income
Tax Act, 1969.

Section 15(1) of the Central Goods and Services Tax Act, 2017 (hereinafter referred to as the
“CGST Act”) provides that the value of the supply of goods and services for levy of GST is
the price actually paid or payable for the said supply or the transaction value where the
supplier and recipient are unrelated and the price is the sole consideration.

The GST Rate of Supply notified under Notification 11/2017-Central Tax dated 28.06.2017,
states that Online Gaming under HSN Code 9984 and HSN Code 9997 would be charged at
18% GST, whereas, Gambling activities under HSN Code 9996 would be charged at 28%
GST.

PROPOSED TAX ON ONLINE GAMING

Recently, a panel of State Finance Ministers (hereinafter referred to as the “Panel”) in their
meeting on taxation of Online Gaming had a discussion with respect to the rate of tax on
Online Gaming where the majority of the States including Tamil Nadu, Meghalaya,
Maharashtra, and Gujarat were open to the idea of levying 28% GST on Online Gaming both
Game of skills and Game of chance. Whereas, States such as Uttar Pradesh and West Bengal
prefer to have different rates for a game of skills and the game of chance.

Explosive Growth in Gaming is Powering Consolidation

The industry registered record growth during COVID – people restricted to their homes
sought to entertain themselves and stay connected, and gaming enabled them to do both – as
more users played multiplayer games, time spent on gaming and related activities increased
by 39%. No surprise, then, that the gaming market was valued at $198.40 bn in 2021, and is
expected to be worth nearly $340 bn by 2027, with mobile games revenue expected to cross
$100 bn by 2023. The gaming industry is larger than the movie and music industries
combined.

Analysis on the Impact of Tencent’s Acquisition of Riot Game

The development of the game industry has led to a surge in cross-border merger and
acquisition activities of game companies. The purpose of this study was to explore the impact
of Tencent Games’ acquisition of Riot games on the company and domestic and foreign
markets. This paper used the Weston Synergy Theory to explore the greater effect brought by
the M&A of Tencent, and chose the SWOT model to qualitatively analyze its impact. This
study concluded that this M&A activity may harm Tencent in the short term, but in the long
run, it can improve Tencent's enterprise efficiency and market competitiveness. Through the
acquisition of Riot's core technology, it can improve the enterprise structure and achieve
economies of scale, resulting in a large number of beneficial effects. Therefore, by analyzing
the positive impact of this acquisition, summing up the experience of cross-border mergers
and acquisitions of game companies, it is helpful to guide other game companies to carry out
cross-border mergers and acquisitions, which has a certain practical significance. However,
based on the market particularity and policy support of this M & A, the guiding significance
of other forms of M & A needs to be further discussed.

Why are companies buying into gaming?

Gaming has always been popular; gamers of the 80s and 90s have grown up and now head
gaming companies. This generation is the first in the industry to have grown up as gamers
themselves. Their passion and understanding of the environment have helped the industry
evolve and are fuelling the drive. That's not to mention the move online over the last decade,
fast-forwarded by the pandemic. With Covid forcing people inside, looking for things to take
up their time and a way to communicate with others, gaming was the perfect outlet.
Immersed in virtual worlds and communicating with other online players, the industry saw a
39% increase in time spent gaming during the initial outbreak of Covid in 2020.
Philippine Law

On 22 September 2021, Republic Act No. 11590 or An Act Taxing Philippine Offshore
Gaming Operators (POGOs) was signed into law by the President.

Salient Changes in the 1997 National Internal Revenue Code, as amended (Tax Code)

● The definition of “offshore gaming licensee” was added to Section 22 of the

Tax Code and shall be considered engaged in doing business in the
Philippines.
● The definition of “offshore gaming licensee-gaming agent” was added to
Section 22 of the Tax Code who acting as such, shall neither be involved with
the business operations of the offshore gaming licensee nor derive income
therefrom.
● Section 125-A of the Tax Code was added to include gaming tax on services
rendered by offshore gaming licensees.

Particula Details
rs

Gaming 5% tax in lieu of all other direct and indirect internal revenue taxes and
tax rate local taxes on the entire gross gaming revenue or receipts or the agreed
predetermined minimum monthly revenue or receipts from gaming,
whichever is higher

Filing On or before the 20th day following the end of each month
and
remittanc
e

● Summarized below are the income tax implication applicable to the following
persons/entities:

Persons/Entities Tax implications

Alien individuals
employed by an offshore
gaming licensee and its
accredited service
providers, regardless of
term and class of working
permit or visa
● Required to have a Tax Identification Number
● Subject to 25% Final Withholding Tax (FWT)
based on gross income earned from all other
sources within the Philippines or
PHP12,500.00 per taxable month, whichever is
higher. (Note: All offshore gaming licensees
and service providers shall submit to the BIR an
original copy of the notarized contract of
employment clearly stating therein the annual
salary and other benefits as well as the
entitlements of the concerned alien.)
(TIN)

In case of failure to withhold and remit the required

taxes of the alien employees, penalties in accordance
with the provisions of the Tax Code will apply and the
concerned alien individual may also be subject to
deportation and may be barred from reentering the
Philippines or blacklisted as a foreign employee.

Offshore Gaming ● Philippine-based (domestic corporations):

Licensees (on non-gaming subject to 25% regular corporate income tax
revenues) based on the taxable income derived during
each taxable year from all sources within and
without the Philippines
● Foreign-based (resident foreign corporations):
subject to 25% regular corporate income tax
based on the taxable income derived during
each taxable year from all sources within the
Philippines
Accredited Service ● Subject to 25% regular corporate income tax
Providers** based on the taxable income derived during

** Provides ancillary each taxable year from all sources within and

services to offshore without the Philippines and to all other

gaming licensees, which applicable local and national taxes;

may include, but shall not ● Not subject to the gaming tax under the new

be limited to, customer Section 125-A of the Tax Code

and technical relations

and support, information
technology, gaming
software, data provision,
payment solutions, and
live studio and streaming
services
 ● Sales to offshore gaming licensees subject to gaming tax under Section 125-A
of the Tax Code are subject to 12% VAT.
● Services rendered to offshore gaming licensees subject to gaming tax under
Section 125-A of the Tax Code, by service providers (including accredited
service providers) are subject to 0% VAT.
● The implementing rules and regulations shall be issued within 90 days after
the effectivity of this law by the Secretary of Finance upon the
recommendation of the Commissioner on Internal Revenue.

Brief

Last Sept. 22, 2021, President Rodrigo Duterte signed into law Republic Act (RA) 11590 or
an “Act Taxing Philippine Offshore Gaming Operations (POGO),” which amends certain
provisions in the National Internal Revenue Code to clarify taxes imposed on POGOs. This
will provide clearer taxation guidelines and will strengthen the power of the Bureau of
Internal Revenue (BIR) to collect taxes from POGOs.

Offshore gaming licensee, as defined by law, refers to an offshore gaming operator, whether
organized abroad or in the Philippines, duly licensed and authorized, through a gaming
license, by the Philippine Amusement and Gaming Corp. (PAGCOR) or any special
economic zone authority, tourism zone authority, or freeport authority to conduct offshore
gaming operations, including the acceptance of bets from offshore customers.

Whereas a service provider is any juridical person, duly created or organized within or
outside the Philippines, or a natural person, regardless of citizenship or residence, which
provides ancillary services to an offshore gaming licensee, or any gaming licensee or operator
with licenses from other jurisdictions. These ancillary services may include customer and
technical relations and support, information technology, gaming software, data provision,
payment solutions, and live studio and streaming services.
All foreign employees of offshore gaming licensees shall have a Tax Identification Number
(TIN). If caught violating this provision, they are liable for penalties of P20,000 for every
foreign national without a TIN. In proper instances, revocation of licenses obtained from
government agencies and prohibition from employing foreign nationals for their operations
may also be imposed.

Recent developments
Republic Act 10963

On 19 December 2017, Republic Act No. 10963, also known as the Tax Reform for
Acceleration and Inclusion (TRAIN) bill, was signed into law and the bill took effect on 1
January 2018. The TRAIN law affects merger and acquisition transactions in the areas of
donor’s tax, Value Added Tax (VAT) and stamp duty (or documentary stamp tax) as
discussed below.

Republic Act 10667

In 2015, one major law was enacted affecting mergers and acquisitions (M&A) in the
Philippines. Republic Act No. 10667, also known as the Philippine Competition Act, was
signed into law on 21 July 2015. It provides for the creation of an independent, quasi-judicial
body called the Philippine Competition Commission.

The law grants the commission the power to review M&A based on factors the commission
deems relevant. Merger and acquisition agreements that substantially prevent, restrict or
lessen competition in the relevant market or in the market for goods or services, as the
commission may determine, are prohibited, subject to certain exemptions.

Effective 1 March 2020, parties to a merger or acquisition agreement with a transaction value
exceeding 2.4 billion Philippine pesos (PHP) and the aggregate annual gross revenues in, into
or from Philippines, or value of the assets in the Philippines of the ultimate parent entity of at
least one of the acquiring or acquired entities, including that of all entities that the ultimate
parent entity controls, directly or indirectly exceeding PHP6 billion are barred from entering
their agreement until 30 days after providing notification to the commission in the form and
containing the information specified in the commission’s regulations. An agreement entered
into in violation of this notification requirement would be considered void and subject the
parties to an administrative fine of 1 to 5 percent of the transaction’s value.

In relation to this, Republic Act No. 11494, also known as Bayanihan to Recover As One,
was signed into law and took effect on 15 September 2020. Pursuant to Section 4 (eee) of
said Act, the Commission issued Memorandum Circular 20-003 which exempts all M&A
with transaction values below PHP50 billion from compulsory notification if entered into
within a period of 2 years from the effectivity of the Act. This is in response to the COVID-
19 pandemic

The Philippine Competition Act also provides that the commission shall promulgate other
criteria, such as increased market share in the relevant market in excess of minimum
thresholds, which may be applied specifically to a sector or across some or all sectors in
determining whether parties to a merger or acquisition should notify the commission.

If the commission determines that such agreement is prohibited and does not qualify for
exemption, the commission may:

● prohibit the agreement’s implementatio

● prohibit the agreement’s implementation until changes specified by the
commission are made
● prohibit the agreement’s implementation unless and until the relevant party or
parties enter into legally enforceable agreements specified by the commission.

The Commission published Memorandum Circulars (MC) Nos. 16-001 and 16-002 on 22
February 2016, and they took effect on 8 March 2016. MC 16-001 provides transitional rules
for M&A executed and implemented after the effective date of the Philippine Competition
Law and before the effective date of its Implementing Rules and Regulations (IRR).
Similarly, MC 16-002 provides transitional rules for M&A of companies listed with the
Philippine Stock Exchange.

Application for tax treaty relief

On 28 March 2017, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum
Order (RMO) No. 08-2017 effective 26 June 2017 regarding the procedures for claiming tax
treaty benefits for dividend, interest and royalty income of non-resident income earners. The
RMO dispensed with the mandatory tax treaty relief application (TTRA) for dividends,
interests and royalties. Instead, preferential treaty rates for dividends, interests and royalties
may now be applied by Philippine withholding tax agents on submission of a Certificate of
Residence for Tax Treaty Relief (CORTT) form.

RMO No. 08-2017 does not apply to other types of income such as business profits and gains
from alienation of property. In these cases, RMO No. 72-2010, as discussed below, applies
and obtaining a ruling is still required.

On 25 August 2010, the BIR issued RMO No. 72-2010, which mandates the filing of a TTRA
for entitlement to preferred tax treaty rates or exemptions. Under current regulations, this is
now limited to income other than dividends, interests and royalties as covered by RMO No.
08-2017. The TTRA must be filed before the occurrence of the first taxable event (i.e. the
activity that triggers the imposition of the tax).

The BIR relaxed the TTRA filing deadline after a Philippine Supreme Court ruling in August
2013. In that case, the BIR denied a TTRA because the taxpayer failed to file their TTRAs
before the occurrence of the first taxable event. The court held that the obligation to comply
with a tax treaty takes precedence over a BIR revenue memorandum.

Summarized below are the tax treatments of various taxpayers affected:

The following transactions are subject to zero percent VAT:

1. Sales of goods and properties to offshore gaming licensees subject to gaming tax
2. Services rendered to offshore gaming licensees subject to gaming tax by service
providers, including accredited service providers

The PAGCOR or other implementing agency shall engage the services of a third-party audit
platform to determine the gross gaming revenues/receipts of each offshore gaming licensee
for submission to the BIR.

Reference:

https://kpmg.com/ph/en/home/insights/2021/09/special-intax-september-2021-issue2-
volume1.html

https://kpmg.com/xx/en/home/insights/2021/04/philippines-taxation-of-cross-border-
mergers-and-acquisitions.html
https://www.grantthornton.com.ph/insights/articles-and-updates1/tax-notes/taxation-of-
philippine-offshore-gaming-operations/

https://cleartax.in/s/tax-on-online-gaming-in-india

https://digitalcommons.usf.edu/cgi/viewcontent.cgi?article=1028&context=globe

https://gupea.ub.gu.se/bitstream/handle/2077/67846/gupea_2077_67846_1.pdf?sequence=1

https://www.nishithdesai.com/fileadmin/user_upload/Html/Hotline/
New_Publication_Ahead_of_the_Game_M.htm