Jumpman Gaming beats HMRC in £13.2m free spins tax case
The UK’s Upper Tribunal has ruled in favor of Jumpman Gaming in its dispute with HM Revenue & Customs (HMRC) over the tax treatment of promotional free spins, wiping out a £13.2m Remote Gaming Duty (RGD) assessment. The ruling, handed down on Friday, overturns part of an earlier decision and closes a case that operators across the UK online casino sector had been watching closely.
The dispute centered on Jumpman’s Mega Reel welcome offer, in which new customers making a qualifying deposit received a free spin of the Mega Reel. That initial spin could then award further free spins on other casino games. HMRC argued the additional spins generated through the promotion should count as gaming payments for RGD purposes, and sought to recover roughly £13.2m ($17.5m) in duty covering accounting periods from July 2018 to December 2022.
Upper Tribunal sides with Jumpman on how the Finance Act’s freeplay exclusion should be read
At issue was the interpretation of section 159A of the Finance Act 2014, which excludes certain freeplay promotions from RGD. A First-tier Tribunal had previously sided with HMRC on the treatment of the follow-on free spins. The Upper Tribunal has now overturned that finding, ruling that HMRC’s approach would have forced operators to trace the origin of freeplay through potentially long chains of prior transactions, an exercise it said did not follow naturally from the legislation. As a result, the additional spins fell within the RGD exclusion.
A partial win for Jumpman
The tribunal did not rule entirely in Jumpman’s favor. The operator separately challenged the First-tier Tribunal’s finding that the initial Mega Reel spin itself was not simply a free version of an otherwise paid-for game, but the Upper Tribunal upheld that part of the earlier decision. Judges noted the Mega Reel displayed a “spin value” that did not necessarily reflect a price customers would otherwise have paid, and that Jumpman’s internal accounting was not visible to customers.
Jumpman also won on a separate procedural point: the Upper Tribunal found that the First-tier Tribunal should have considered government consultation documents published before RGD rules changed in 2017, which showed the government had opted to tax only the first use of a freeplay.
Wider exposure for Super Group and rivals
The case has implications beyond Jumpman itself. Evoke, owner of William Hill, disclosed in its FY2025 accounts a potential £17.6m exposure if HMRC had succeeded and pursued other operators for under-declared RGD, though it did not recognise a provision for that amount. Super Group, which owns both Jumpman and Betway, took a different approach after the earlier First-tier Tribunal defeat, recording a related $26.4m provision in its 2025 annual report, of which $16.9m related to RGD and the remainder to estimated penalties and interest. Super Group acquired a majority stake in Jumpman in September 2022 and the remaining stake in 2024; Jumpman operates around 200 brands and generates nearly all of its revenue in the UK.
The ruling lands as RGD has risen from 21% to 40% as of 1 April 2026, raising the stakes of freeplay tax treatment for casino-focused operators going forward. HMRC may still seek permission to appeal the decision.
