- Status
- Dismissed (dismissed)
- As of
- 27 Nov 2020 · read from the court record
- Court
- UK Supreme Court (from [2018] EWCA Civ 2210; [2016] UKUT 259 (TCC); [2014] UKFTT 1060 (TC)) · Supreme or high court
- Docket
- [2020] UKSC 49
- Judge
- Lord Carnwath, Lady Black, Lady Arden, Lord Kitchin, Lord Sales
- Filed
- not on record
- Type
- Operator v. regulator, gambling tax litigation
- Money
- No settlement fund or award on record
- Payout
- No payout exists as of 14 Nov 2026
Status words follow the court record: a complaint states one side's allegations, only the court's orders decide anything. Filing a settlement claim is always free.
What this case is about
Casinos hand high rollers non-negotiable chips and free bet vouchers; HMRC said these were stakes at face value for gaming duty. The Supreme Court dismissed HMRC's appeal on 27 November 2020: non-negs are not stakes with money value for s.11(10)(a) and are not valued at face value when returned as prizes.
What this case is about
HMRC v London Clubs Management Ltd, [2020] UKSC 49, is a UK Supreme Court appeal about gaming duty on non-negotiable chips and free bet vouchers. The Commissioners for HM Revenue and Customs appealed against London Clubs Management Ltd.
Casinos hand high rollers non-negotiable chips ("non-negs") and free bet vouchers. HMRC said these were stakes at face value for gaming duty. The question was whether they are "stakes staked" and how they are valued under section 11(10) of the Finance Act 1997.
The case reached the Supreme Court from [2018] EWCA Civ 2210, [2016] UKUT 259 (TCC) and [2014] UKFTT 1060 (TC). It is one of the cases in Gambling Tax Litigation.
Who is covered
The ruling concerns casino operators liable to UK gaming duty and the way they count non-negotiable chips and free bet vouchers. It does not cover individual players, and no class exists.
The five Justices were Lord Carnwath, Lady Black, Lady Arden, Lord Kitchin and Lord Sales. The country page Gambling Lawsuits in United Kingdom lists the other UK cases.
Is there a payout?
No payout exists in this case. It is a tax dispute between a revenue authority and a casino operator, and the record shows no fund, damages or settlement for players.
There is no claim to file and no deadline. A tax ruling of this kind changes how much duty an operator owes the state, not what any player receives.
What the court decided
The Supreme Court dismissed HMRC's appeal on November 27, 2020. It held that non-negs are not stakes with a money value for section 11(10)(a) of the Finance Act 1997.
The Court also held that non-negs are not valued at face value when they are returned as prizes. HMRC's position on face value therefore failed.
The case is recorded as dismissed, with no later step listed as of November 14, 2026.
The practical effect is that a casino does not owe gaming duty on the face value of non-negs it hands out or takes back as prizes. The record lists no step after the Supreme Court judgment.
Why it matters
The record classes this case as a precedent. It fixes how UK casinos treat promotional chips and vouchers when they calculate gaming duty.
It sits beside the tax disputes over the Rank Group and the Hippodrome Casino, listed below. Tax on money a player receives from a settlement is a different question, covered in Are Gambling Settlement Payments Taxable.
Questions people ask
What are non-negotiable chips?
Non-negotiable chips are chips a casino hands to high rollers that are not cashed in as money. Free bet vouchers work in a similar way, and HMRC argued both counted as stakes at face value.
Did the Supreme Court side with HMRC?
No. On November 27, 2020 the Supreme Court dismissed HMRC's appeal in [2020] UKSC 49 and held that non-negs are not stakes with money value for gaming duty.
Related cases
- HMRC v The Rank Group plc: a gaming duty case with status dismissed.
- HMRC v Hippodrome Casino Ltd: a related HMRC gaming duty case with status judgment.
Who is involved
Plaintiffs: Commissioners for HM Revenue and Customs (appellant)
| Defendants | London Clubs Management Ltd |
|---|---|
| Judge | Lord Carnwath, Lady Black, Lady Arden, Lord Kitchin, Lord Sales |
| Claims |
|
Is there a payout?
No payout exists in this case as of 14 Nov 2026.
What happens next
No future date is on the record we hold. The case is closed on the record we hold; later appeals or enforcement steps would be added here.
Timeline
1 dated step on record, oldest first. Future dates come from court notices and can move.
| Date | Event |
|---|---|
| 27 Nov 2020 | Dismissed |
Documents and sources
1 primary source (court file, administrator notice, regulator) and 0 secondary. Press is supporting evidence only.
- Docket: caselaw.nationalarchives.gov.uk
| What it supports | Source | Type | Retrieved |
|---|---|---|---|
| judgment, issue, disposition | caselaw.nationalarchives.gov.uk | primary | 14 Nov 2026 |
Related cases
2 cases in the record share parties, claims or a settlement with this one.
| Case | Court | Status |
|---|---|---|
| Rank v HMRC (VAT on slot machines, Supreme Court) | UK Supreme Court (from [2013] EWCA Civ 1289) | Dismissed |
| Hippodrome Casino v HMRC (VAT partial exemption) | Upper Tribunal (Tax and Chancery Chamber), from [2022] UKFTT 110 (TC) | Judgment entered |
Last checked against the sources on 14 Nov 2026. Found an error? Tell us and we correct the record with a dated note.