Upper Tribunal quashes Jumpman Gaming's £13.2m HMRC tax bill
A UK Upper Tribunal ruling has zeroed out a Remote Gaming Duty bill issued to Guernsey-based slots operator Jumpman Gaming, overturning an earlier First-tier Tribunal decision on free spins and re-wagering.
Jumpman Gaming has had a £13.2m Remote Gaming Duty bill from HM Revenue and Customs reduced to nothing, at least for now, after winning a case at the Upper Tribunal, according to SBC News.
The Guernsey-based operator, which mainly supplies online slots, had been assessed by HMRC over the period from July 2018 to December 2022. The dispute centred on one of Jumpman's promotional products, Mega Reel, and whether winnings generated from free spins and subsequently re-wagered on the site should count as taxable revenue.
HMRC's position was that money won through free spins and then staked again on the casino represented income that fell within scope of RGD. Jumpman disputed the inclusion of Mega Reel in that assessment.
The operator first took the case to the First-tier Tribunal, which ruled in HMRC's favour in September 2025. Jumpman then appealed to the Upper Tribunal, which has now reversed two of the lower tribunal's findings.
According to SBC News, the Upper Tribunal found that the First-tier Tribunal had wrongly excluded 2016 pre-legislative consultation materials from its consideration, and had also interpreted the phrase "the gaming" too narrowly in a way that failed to capture further free spins won by customers.
The case turned on wording in the Finance Act 2014, which underpins RGD and defines gaming, profit valuations and gaming payments. A key clause exempts prizes "won in the course of the person's participation in the gaming" from duty. HMRC argued this applied only to games where the operator had waived the normal cost of play, such as depositing and staking. Jumpman argued it covered gambling more broadly, including Mega Reel.
The First-tier Tribunal had sided with HMRC on the basis that Mega Reel is a free-to-play game. The Upper Tribunal has now ruled that funds wagered from free spins won via an initial promotional free spin should be exempt from RGD.
The Finance Act 2017 was also central to the case, as it specifically addresses promotional offers including free spins, bonus credits and matched deposits, and sets out exclusions for re-wagered funds under RGD.
All UK-licensed operators remain subject to the Gambling Act 2005, which governs licensing and conduct and was reviewed between 2020 and 2023, while RGD and other duties sit under separate finance legislation.
The ruling arrives as taxation remains a live concern for the UK gambling industry following the increase in RGD from 21% to 40% in April 2026, a change the sector has criticised, with knock-on implications for Machine Games Duty. SBC News notes the Jumpman case is unrelated to that increase but lands at a moment when tax policy is high on the agenda for iGaming finance and compliance teams.
HMRC retains the right to appeal the Upper Tribunal's decision, meaning the £13.2m liability could yet be revisited.