Taxation of gambling in the UK

FORTHCOMING CHANGES: At Budget 2025, the government decided not to introduce a single remote betting and gaming duty, as was initially proposed in a consultation earlier in the year, on the basis that remote betting (wagering on real-world events with variable odds) and remote gaming (games of chance) have distinct characteristics and levels of harm associated with them and should therefore be taxed differently. Instead, the government announced that it will:

  1. increase the rate of remote gaming duty from 21% to 40% from 1 April 2026 to reflect the greater harm associated with remote gaming, and

  2. introduce a new 25% rate of GBD for remote betting from 1 April 2027. Remote betting on UK horse racing will be excluded from the new rate, as will any bets placed via self-service betting terminals on licenced premises. These will instead remain chargeable at a rate of 15%

The government also announced that:

  1. bingo duty will be abolished from 1 April 2026

  2. legislation will be introduced to fill a gap in HMRC’s powers to levy penalties for errors in

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Market value, distributions and notional transactions—key SDLT lessons from Tower One St George Wharf Ltd v HMRC

Tax analysis: In Tower One St George Wharf Ltd v HMRC, the Court of Appeal considered the basis on which stamp duty land tax (SDLT) should be assessed and whether that resulted in SDLT being paid on the market value; the actual consideration paid; or on some other basis for a complex transaction within a corporate group. The taxpayer argued that the ‘Case 3’ exception under section 54(4) of the Finance Act 2003 (FA 2003) applied, which would result in SDLT being charged on the actual consideration. HMRC argued that the exception did not apply, which would result in SDLT being paid on the market value of the property. Alternatively, HMRC argued that if the exception did apply then the anti-avoidance provisions at section 75A FA 2003 applied, potentially resulting in an even higher SDLT charge. The Court of Appeal held that although the Case 3 exception applied, the anti-avoidance provision in FA 2003, s 75A also applied. This resulted in SDLT being assessed on an aggregate amount that was even higher than the property's market value (although HMRC did not seek to increase its assessment beyond market value). Therefore, the appeal was dismissed. As explained by Jon Stevens, partner, and Rory Clarke, solicitor, at DWF Law LLP, this decision deals with the interaction of a number of complex SDLT provisions; clarifies the SDLT provisions relating to transfers to connected companies; and the SDLT anti-avoidance provisions, with implications for corporate structuring and tax planning.

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