Court of Justice 11 September 2025, C-472/24 (Opinion of Advocate General Kokott delivered on 11 September 2025.)

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Advocate General Kokott opines that the sale of in-game Gold (from the online game RuneScape) for real money does not fall within the VAT exemption under Article 135(1)(e) of Directive 2006/112/EC, as in-game Gold is neither legal tender nor a non-legal tender accepted as a contractual direct means of payment between operators with no other purpose than to serve as a means of payment in legal transactions. The AG further opines that in-game Gold does not qualify as a multi-purpose voucher within the meaning of Article 30a of the VAT Directive, since it constitutes a consumable electronic service in itself rather than an instrument obligating the issuer to supply a future, unspecified service. On the taxable amount, the AG proposes a teleologically broader, mutatis mutandis application of the margin scheme under Article 311 et seq. of the VAT Directive to tradable non-tangible services—including in-game objects—that are traded on a secondary market in a manner comparable to second-hand goods and typically contain residual VAT, leaving it to the referring commission (Tax Disputes Commission under the Government of the Republic of Lithuania, Mokestinių ginčų komisija prie Lietuvos Respublikos Vyriausybės) to determine whether those conditions are met for in-game Gold in the present case.AI