HMRC v London Clubs Management

Cathya Djanogly

In HMRC v London Clubs Management [2018] EWCA Civ 2210 (9 October 2018) the Court of Appeal found that non-cash inducements given to favoured customers by casinos had nil value for the purpose of gaming duty under FA 1997 s 11(10)(a).

London Clubs Management (LCM) runs casinos. It provides selected customers with means of placing bets free of charge: free bet vouchers; and non-negotiable chips (referred to collectively as ‘non-negs’). The issue was whether a player who places a bet in one of LCM's casinos using non-negs has staked ‘value in money or money's worth’ with the casino for the purpose FA 1997 s 11(10)(a). If the value staked by a player was nil non-negs would reduce the overall amount of gaming duty due by casinos.

The Court of Appeal observed that the purpose of s 11(10) is ‘clearly to charge duty on the profits of...

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