UK online casino operator Jumpman Gaming Ltd has secured a milestone victory in the Upper Tribunal under case reference [2026] UKUT 00364 (TCC). The company successfully set aside Remote Gaming Duty (RGD) tax assessments issued by HM Revenue and Customs (HMRC) totalling approximately £13.2 million for the period between July 2018 and December 2022.
The official judgment is published on the GOV.UK tribunal decision register (full text available in PDF).
Background and Promotional Mechanics
The central point of contention was the operator’s multi-stage welcome promotion:
- Welcome Mega Reel Spin: Upon making an initial deposit, players received a spin on a promotional wheel.
- Awarding of Free Spins: The prizes from this wheel frequently consisted of free spins (Further Free Spins) on specified slot games.
HMRC maintained that these secondary free spins constituted taxable "deemed gaming payments" under section 159(4) of the Finance Act 2014 (as amended in 2017) and refused to apply the statutory relief under section 159A.
Key Rulings of the Upper Tribunal
Reviewing the earlier First-tier Tribunal decision (FTT [2025] UKFTT 1117 (TC)), the Upper Tribunal reached the following conclusions:
- Ground 1 (Dismissed): The Tribunal agreed with HMRC that the initial spin of the Welcome Mega Reel was a "free game" rather than gaming where participation fees were waived.
- Ground 3 (Allowed — Core Victory): The primary legal battle turned on the interpretation of "the gaming" in section 159A(4)(b) FA 2014. HMRC argued the relief applied strictly to direct stake waivers. The Tribunal rejected this narrow view, holding that free spins won inside a promotional game fall squarely within the relief exemption under section 159A(4)–(5).
- Ground 2 (Allowed): The Tribunal confirmed that the FTT erred in law by refusing to consider official government consultation documents from the 2016–2017 tax reforms when ascertaining legislative intent.
Industry Impact
Because HMRC’s assessment was built on an incorrect reading of section 159A(4)(b) FA 2014, the Upper Tribunal discharged the assessment in full, reducing the £13.2 million demand to zero. The ruling establishes an essential legal precedent for gambling operators in the UK navigating RGD liabilities on multi-tier promotional campaigns.
