Jumpman Gaming has overturned a £13.2m Remote Gaming Duty assessment from HMRC following an Upper Tribunal ruling that reversed two key findings of the lower court. The dispute centred on whether winnings from free spins, when re-staked by players, constitute taxable gaming payments.
HMRC had billed Jumpman for July 2018 through December 2022, arguing that funds won via the Mega Reel promotional feature and subsequently wagered should count as operator profit subject to RGD. Jumpman contested the assessment on the grounds that the promotion was free and the charge improper. The First-tier Tribunal sided with HMRC in September 2025, but the Upper Tribunal found that the lower court had wrongly excluded 2016 guidance material and misread the statutory phrase "the gaming" — which extends to further free spins won during a promotion.
The case turned on Finance Act 2014, which sets out RGD and defines gaming payments, and Finance Act 2017, which covers promotional offers including free spins, bonus credits and deposit matches. The 2014 statute contains a carve-out for funds "won in the course of participating in the gaming". HMRC took that to mean games where the operator waived the usual entry cost; Jumpman argued it applied to gambling more broadly, including Mega Reel. The Upper Tribunal agreed that stakes derived from promotional free-spin winnings fall outside RGD scope.
The ruling sets a precedent as RGD rises from 21 % to 40 % in April 2026. HMRC retains the right to appeal.
