On June 12, 2026, the UK Court of Appeal ruled that Bolt’s ride-hailing services do not qualify for the Tour Operators Margin Scheme (TOMS). The decision overturned earlier tribunal rulings in Bolt’s favor and required the company to pay approximately GBP 190 million in outstanding VAT. Dissatisfied with the ruling, Bolt appealed to the UK Supreme Court.

Background of the Case and Supreme Court's Ruling

The Supreme Court noted that Bolt operates a ride-hailing platform that connects passengers with private hire drivers. Since August 2022, Bolt has acted as the principal in the transport service, purchasing transport from self-employed drivers and reselling it to passengers under separate contracts. As a result, Bolt supplies the transport service to passengers rather than the drivers directly.

The dispute concerned whether Bolt could apply the TOMS, a simplified VAT scheme that allows eligible businesses to account for VAT on their profit margin rather than the full selling price. Bolt argued that its services qualified for the scheme, while HMRC maintained that ride-hailing services fell outside its scope. If TOMS applied, Bolt would account for VAT only on its margin. Conversely, VAT would apply to the full fare received from passengers.

The First-tier Tribunal ruled in Bolt’s favor in December 2023, finding that its services were of a kind commonly provided by tour operators or travel agents. The Upper Tribunal subsequently upheld that decision. However, the Court of Appeal overturned the earlier rulings and sided with HMRC. 

The Court of Appeal concluded that Bolt’s ride-hailing services were not services of a kind commonly provided by tour operators or travel agents and therefore did not qualify for TOMS. Under this interpretation, VAT must be charged at 20% on the full fare paid by passengers rather than only on the margin between the fare and the amount paid to drivers. 

On October 2, 2026, the UK Supreme Court refused permission to appeal, finding that the application did not raise an arguable point of law of general public importance that the Court should consider at this stage. 

Decision's Impact

Because the Supreme Court denied permission to appeal, the Court of Appeal’s ruling stands. Consequently, Bolt’s ride-hailing services remain outside the scope of the TOMS. The ruling could also significantly affect the ongoing HMRC dispute with Uber, which concerns approximately GBP 1.4 billion in VAT.