On 12 June 2026, the Court of Appeal handed down judgment in HMRC v Bolt Services UK Limited [2026] EWCA Civ 720, allowing HMRC’s appeal against the decision of the Upper Tribunal concerning the VAT treatment of Bolt’s ride‑hailing services.
Bolt operates a platform through which customers can book private hire vehicle journeys via a mobile app. In 2022, Bolt challenged HMRC’s decision that the Tour Operators’ Margin Scheme (“TOMS”) did not apply to its services. The First-tier Tribunal (FTT) allowed Bolt’s appeal, and the Upper Tribunal upheld that decision, finding that Bolt’s services fell within the scheme on a broad, “high‑level” approach. HMRC appealed, arguing that the tribunals had been wrong to treat Bolt’s services as comparable to those supplied by travel agents or tour operators.
The Court of Appeal allowed HMRC’s appeal. It held that the scheme applies only where the services in question are identical or at least comparable to those supplied by travel agents or tour operators. The Court rejected the tribunals’ approach and concluded that the scheme did not apply to Bolt’s business model.
Eleni Mitrophanous KC acted for HMRC, instructed by the HMRC Legal Group.
Read the full judgment here.