UK Rewrites Free Spins Rules for Remote Gaming Duty After Jumpman Gaming Wins £13.2 Million Tribunal Case

The UK government will rewrite the Remote Gaming Duty rules on free spins and other promotional play from 1 April 2027, HM Revenue & Customs (HMRC) said in a Budget document published on 28 October 2026, about five weeks after online operator Jumpman Gaming persuaded the Upper Tribunal to wipe out a £13.2 million tax bill on free spins. The change will be written into Finance Bill 2026-27 and does not reach back to the years covered by the Jumpman case.

Remote Gaming Duty (RGD) is the tax on profits from online casino games, slots and other remote gaming offered to UK customers. Its rate rose from 21% to 40% on 1 April 2026, which makes every pound of promotional play that counts as a taxable stake more expensive for operators.

What the Budget changes

HMRC's tax information and impact note sets out a new framework built around "restricted plays," the term that will replace "freeplays." The Budget's Overview of Tax Legislation and Rates (OOTLAR) lists the measure as one that will "put beyond doubt the tax treatment" of freeplays, prizes and tournaments.

The note says the measure replaces section 159A of the Finance Act 2014, the provision added by the Finance (No. 2) Act 2017 to bring freeplays into the duty. HMRC scores the exchequer impact at nil for every year to 2031-32, describing it as a compliance measure that reinforces existing policy and protects future revenue.

The Jumpman Gaming case

The note does not name Jumpman Gaming. It says only that "different interpretations have arisen" over the 2017 rules. The new exclusion wording, though, targets the point HMRC lost in court, and NEXT.io and other trade outlets have linked the two.

Jumpman ran slot-style online games. New customers who deposited received one free spin on its "Mega Reel," a game of chance that could award free spins on other games. HMRC assessed duty on those follow-on spins for July 2018 to December 2022.

The First-tier Tribunal, led by Judge Amanda Brown KC, held that the Mega Reel spin was a free game rather than a game played for free, so it carried no taxable stake; Jumpman had in fact over-accounted for duty on it. But the tribunal sided with HMRC on the follow-on spins, reading "the gaming" in section 159A(4) as gaming played under a waived-stake offer.

The Upper Tribunal, Judges Swami Raghavan and Guy Brannan, preferred Jumpman's wider reading. In its ruling, [2026] UKUT 364 (TCC), it found the follow-on spins fell within the exclusion for freeplay won in the course of gaming, and reduced the assessments to nil, according to Solicitors Journal's case report.

Bryn Reynolds, a tax partner at Pinsent Masons, told Out-Law the result seemed "to defeat the purpose of the 2017 amendments" and predicted HMRC might change the law, as it did after a similar loss in insurance. The Budget measure does that, but only from April 2027.

What it means for operators

The new rules close the route Jumpman used: a free spin that comes from a free game, rather than from another restricted play, will no longer fall inside the exclusion. Bonus money that players cannot withdraw is also brought expressly within restricted play.

HMRC expects negligible one-off costs for operators to learn the rules. The impact is larger for those that built promotions on the Upper Tribunal's reading, at a time when the 40% rate already weighs on marketing budgets and the UK Gambling Commission has been reworking its rules on incentives since its 2023 consultation on bonuses and free bets. Other markets are taxing promotions directly; Colombia, for example, applies separate tax rules to player bonuses.

Part of a wider Budget package

The free spins change sits beside the Machine Games Duty rise to 25% on higher-stake machines in Chancellor John Healey's Budget, which also starts on 1 April 2027, the same day the 25% rate on remote betting under General Betting Duty begins. Both follow the November 2025 package that raised RGD from 21% to 40% after the consultation on a single remote betting and gaming duty kept separate duties. Online operators had escaped any rise in October 2024, when gambling shares rallied after the 2024 Budget.

What happens next

The measure will appear as draft clauses in Finance Bill 2026-27 and can be amended during its passage through Parliament. HMRC has not said publicly whether it will try to take the Jumpman case to the Court of Appeal, which is now the only route to restore the 2018 to 2022 assessments.

Status reviewed on 30 October 2026. The measure's details are from HMRC's impact note and the Budget 2026 OOTLAR; tribunal findings are from the First-tier Tribunal decision and published case reports of the Upper Tribunal ruling. More legislation news and EMEA coverage.