Bolt Services UK Limited (Appellant) v Commissioners for His Majesty’s Revenue and Customs (Respondent)

Case summary

Case ID

UKSC/2026/0096

Parties

Appellant(s)

Bolt Services UK Limited

Respondent(s)

His Majesty's Revenue and Customs

Issue

Do mobile ride-hailing services fall within the scope of the Tour Operators’ Margin Scheme (“TOMS”), a simplified accounting scheme for certain tour operators or travel agents for the purposes of the Value Added Tax Act 1994 (“VATA”)?

Facts

The appellant, Bolt Services UK Limited (“Bolt”), is part of a group of companies which provide a platform offering a range of services, including transport by private hire vehicle, in over 400 cities worldwide. Bolt is licensed as a private hire vehicle operator in the United Kingdom. The platform allows Bolt’s customers to request a private hire vehicle to take them to their requested destination by using an app, allocating them to a specific private hire vehicle driver who is willing to transport them. From August 2022, Bolt has acted as principal in the re-supply of passenger transport by private hire vehicles, which Bolt buys from self-employed private hire vehicles. Bolt enters into a contract with the driver and a separate contract with the passenger, with the result that there is no contract between the driver and the passenger. In October 2022, Bolt asked the respondent, Commissioners for His Majesty’s Revenue and Customs (“HMRC”), to make a non-statutory ruling that the TOMS regime applied to Bolt’s services. TOMS is a simplified VAT accounting scheme for tour operators or travel agents that buy in and sell on travel services such as passenger transport and hotel accommodation. If outside the TOMS regime, Bolt would account for VAT on the full fare received from its customers in the normal way. If inside the TOMS regime, it would only account for it on a smaller portion, being Bolt’s ‘margin’ that it received for that fare. HMRC decided that Bolt’s supplies of mobile ride-hailing services do not fall within the scope of TOMS. Bolt appealed this decision to the First-tier Tribunal (Tax Chamber) (the “FTT”) and, in December 2023, the FTT allowed Bolt’s appeal. The FTT held that Bolt’s supplies were services “of a kind commonly provided by tour operators or travel agents” and were not excluded from the regime. HMRC appealed the FTT decision to the Upper Tribunal. The Upper Tribunal dismissed HMRC’s appeal. HMRC appealed to the Court of Appeal. The Court of Appeal allowed HMRC’s appeal. The Court of Appeal held that Bolt’s supplies were not services of a kind commonly provided by tour operators or travel agents. Bolt now appeals to the Supreme Court of the United Kingdom.

Date of issue

10 July 2026

Case origin

PTA

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