12 Aug 2026: Ride sharing platform in Supreme Court appeal after losing £190m ruling on using low VAT rate Tour Operators Margin Scheme
The ride sharing platform, Bolt, has applied to the UK Supreme Court to appeal a 12 June 2026 Court of Appeal ruling that it was not entitled to apply the reduced VAT rate Tour Operators Margin Scheme. The right for a hearing at the Supreme Court is not automatic, and is now under consideration.
The Court of Appeal had backed HMRC, and held that Bolt’s supplies were not services of a kind commonly provided by tour operators or travel agents.
12 June 226: Ride sharer loses Court of Appeal £190m TOMS ruling
On 12 June 2026, the UK Court of Appeal ruled that ride sharing platform, Bolt, could not take advantage of the TOMS scheme. Meaning if will have to charge full 20% UK standard VAT on the entire fare.
The case centred on whether Bolt’s app-based services, where it acts as principal in supplying transport from self-employed drivers, should qualify under TOMS. The driver remains independent, so Bolt is not the principal in the transaction and therefore not responsible for full VAT.
The court ruled Bolt’s service are not compatible with services provided by travel agents.
This reversal means Bolt will have to charge VAT on the whole ride fare instead of just it’s margin.
March 2024: Bolt wins appeal on TOMS
A UK’s Upper Tribunal on 24 March 2025 rejected HMRC’s appeal to block ride sharer Bolt from using TOMS. Dec 2023: First Tier Tribunal backs Bolt for lower VAT
First-tier tribunal case has ruled in favour of deliver service operator, Bolt, over HMRC. The tribunal ruled that these mobile ride-hailing services are passenger transport, commonly provided by tour operators or travel agents, and therefore falls within the scope of TOMS.
Bolt is therefore only liable to 20% standard VAT on its margin of the service, and not the full amount charged to the customer.
Ruling to boost Uber’s UK case?
The ruling may influence the ongoing Uber UK VAT liability, which the ride sharer has made provision for £386m in its latest financial statements. This was on the basis that it would not qualify as a TOMS service and would have to repay full VAT to HMRC.
Bolt, like Uber, offers mobile ride-hailing services on-demand via smartphone applications. It sought assurance from HMRC that it qualified for use of the Tour Operators Margin Scheme (TOMS). This was declined by HMRC, and the matter referred for this decision.
HMRC now has the opportunity to appeal this decision.
