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R (oao Thomas Holdings Ltd and others) v HMRC

How do random number generators work?

In R (oao Thomas Holdings Ltd and others) v HMRC [2025] EWHC 1660 (Admin) (8 July) the High Court (HC) dismissed claims for judicial review in a case which concerned assessments made for Amusement Machine Licence Duty (AMLD) for periods to 31 July 2006. The HC found that HMRC acted reasonably in refusing to apply Extra Statutory Concessions (ESCs) 3.4 and 3.5.  

ESC 3.4 (misunderstanding) and ESC 3.5 (misdirection) related to VAT and are now obsolete but HMRC accepted that they could potentially apply in the circumstances of the case. As explained below the case is relevant to the continuing concept of legitimate expectation.  

The background to the case is that under the Betting and Gaming Duties Act 1981 s 25 a feature of a game played on a gaming machine is that the outcome of the game is determined by...

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