On 5 March 2026, the Court of Justice of the European Union (CJEU) ruled in Case C-472/24 that the sale of RuneScape in-game virtual gold is subject to Value Added Tax (VAT). The court clarified that this virtual currency does not qualify for VAT exemption under Article 135(1)(e) of the EU VAT Directive and does not constitute a multi-purpose voucher under Article 30a(3). As a result, VAT applies to the full consideration received for each sale, establishing an important precedent for the tax treatment of virtual currencies and electronic services in online gaming.
Background: Lithuanian Company Case
MB "Žaidimų valiuta", a Lithuanian company, bought and resold RuneScape virtual gold in exchange for euros between 2020 and 2023. A tax audit revealed that the company had not declared or paid VAT on these transactions.
The company challenged the resulting tax order on two grounds:
That RuneScape gold qualifies as a VAT-exempt virtual currency under the Hedqvist (C-264/14) doctrine.
That, if not a currency, it qualifies as a multi-purpose voucher, subject only to margin taxation.
The Lithuanian Commission for Tax Disputes referred both questions to the CJEU for a preliminary ruling.
Why RuneScape Gold Is Not a Virtual Currency
The CJEU applied the two-condition Hedqvist test:
The currency must be accepted as an alternative means of payment to legal tender.
It must serve no purpose other than as a means of payment.
RuneScape gold fails both conditions:
It operates exclusively within the RuneScape game and is not accepted outside the game environment.
The game’s terms of use explicitly state that in-game items do not belong to players.
By contrast, cryptocurrencies like Bitcoin meet both Hedqvist conditions and may retain VAT-exempt status.
RuneScape Gold Is Not a Multi-Purpose Voucher
The CJEU also rejected the multi-purpose voucher argument. An instrument qualifies as a voucher only if it carries an obligation to be accepted as consideration for a future supply of goods or services. RuneScape gold does not meet that requirement, as the gold is itself the electronic service consumed within the game, not a token that grants access to a separate future benefit. If a player spends 1,000 units of in-game gold to equip a character, the gold spent is the service itself, not an instrument redeemed for a subsequent supply.
VAT on the Full Sale Price
Since RuneScape gold classifies as an electronic service, the taxable amount is the total consideration received per sale under Article 73 of the VAT Directive. The margin scheme does not apply.
Key Takeaways
RuneScape in-game gold is taxable under EU VAT law.
It does not qualify as a VAT-exempt virtual currency or a voucher.
Businesses dealing in virtual goods and currencies in the EU must comply with VAT obligations.
About the Author
This article has been authored by Matthew Farrugia, VAT Coordinator.
