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END OF APPEALS ROAD: Bolt refused Supreme Court appeal in £190m VAT dispute
Bolt has been refused permission to appeal to the Supreme Court in its long-running dispute with HM Revenue and Customs over how it calculates VAT on passenger journeys.
The decision follows HMRC’s successful appeal in June, when the Court of Appeal overturned earlier rulings in Bolt’s favour. The tax authority had challenged the company’s use of the Tour Operators’ Margin Scheme (TOMS), under which VAT is paid on an operator’s margin rather than the full fare.
The dispute concerns whether Bolt should account for VAT only on the commission it retains from a journey, or on the entire fare paid by the passenger. The case involves an estimated £190 million in unpaid VAT.
The Supreme Court refused Bolt’s application, saying it “does not raise an arguable point of law of general public importance which the Supreme Court ought to hear at this time.”
Bolt’s senior general manager for the UK and Ireland, Kimberly Hurd, said the company was disappointed by the decision. “Two courts have already found in Bolt’s favour on this question. We are therefore disappointed that the Supreme Court has refused permission for Bolt to appeal the Court of Appeal’s findings.”
Hurd said the tax treatment had implications for the wider market. “Businesses need a tax framework that supports a competitive market. This has consequences for fares, for driver earnings and for consumer choice across the sector that earlier rulings provided – supporting the 100,000 drivers that earn through our platform, and the millions of passengers that have depended on affordable and accessible transport,” she added.
The Government has separately changed the law from 2 January 2026, requiring VAT to be accounted for on the full value of taxi and private hire journeys rather than only on the operator’s margin. The Bolt case concerns the historic tax treatment and the sums potentially due under it.
Sue Rathmell, VAT partner at MHA, said: “This brings to an end a long-running dispute over whether taxi and private hire operators such as Bolt and Uber could use the Tour Operators' Margin Scheme (TOMS) to reduce the amount of VAT they paid on journeys.
“Under TOMS, VAT is only payable on the operator's margin rather than the full value of the fare. HMRC has argued for several years that the scheme was never intended to apply to ride-hailing businesses, while operators maintained that they were entitled to use it under the existing legislation.
“The Government had already moved to close the issue for the future by changing the law from 2 January 2026, meaning VAT must be accounted for on the full value of taxi and private hire journeys rather than just the margin. However, these cases were about the historic position and the potentially enormous sums at stake.
“The Supreme Court's decision to refuse Bolt permission to appeal means HMRC's victory at the Court of Appeal now stands. Uber's case was effectively waiting in the wings behind Bolt, so this decision is likely to bring the wider litigation to a close.
“The amounts involved are significant. It has been estimated that the use of TOMS was worth at least £290 million to Bolt alone, with an even greater value for Uber and more than £1 billion across the industry as a whole. The decision therefore represents a major win for HMRC and provides long-awaited certainty for the sector after years of litigation and legislative change."
