Inside Asian Gaming

shall be deemed to be a moneylender for the purposes of the Moneylenders Act (Cap. 188); and (b) lends money in accordance with this section shall be deemed not to be a moneylender for the purposes of the Moneylenders Act.” If, however, a checked in ‘VIP’s’‘friend’ were present in a VIP room at one of the Singapore IRs and had access to fewer than S$100,000- worth of chips, he or she could also technically be in breach of Part 1, sub-section 3 of the casino credit regulations. In order to qualify as a ‘premium’ (VIP) player: “the total amount of money, chips or any cheque or traveller’s cheque credited to the patron’s deposit account in accordance with paragraph (2) is not less than $100,000 [Singapore].” The only exception is if the player is a supplied with credit by a junket registered by the Singapore authorities, which would clearly not apply in an informal arrangement between ‘friends’. Tax issues There could also be the small matter of potential tax avoidance. A bona fide individual VIP checking in a minimum of S$100,000 for personal use is entitled under Singapore law to pay a discounted tax rate on the gross of five percent gaming tax (plus seven percent GST). But were an off duty junket rep to pass those chips to several ‘friends,’ each ‘friend’would be playing with chips valued below the VIP check in level. Those people should in theory not then be classified as premium players, but as ‘mass market’ players, and should in theory be paying gaming tax rated at 15% of the gross (plus GST). An interesting question is would the burden of proof be on the individual VIP customer checking in to prove he or she was a bona fide ‘individual’ and not acting in the capacity of a junket rep, or would the burden of proof be on Singapore’s Casino Regulatory Authority to prove the person was a junket rep in disguise? One wonders also whether the Singapore authorities went to the trouble of ‘stress-testing’ their junket regulations with a consultant with inside knowledge of junket operations before passing them into law. That would certainly have been a valuable exercise, given Asian junkets’ reputation across the industry for what might charitably be called creative thinking. We await with interest the CRA’s response to these claims. Marina Bay Sands—junkets present in disguise?