On June 12, 2026, the UK Court of Appeal ruled in a highly anticipated case between the HMRC and Bolt, an Estonian-based ride-hailing and ‌food delivery company. In addition to settling a vital dispute between these parties, the decision is also relevant to an ongoing case between HMRC and Uber, which has been paused for 35 days pending full resolution of the Bolt case at all appeal levels.

Impact of the Court's Decision

At the center of the dispute between the HMRC and Bolt lies a question of whether Bolt's ride-hailing services qualify under the Tour Operators Margin Scheme (TOMS). Bolt argues that they do, and that it should pay VAT only on the margin between the ride cost charged to passengers and the amount paid to drivers, contrary to HMRC's claims that VAT should be applied to the full amount paid for the ride.

Both the First-tier Tribunal (FTT) and the Upper Tribunal Tax (UTT) ruled in favour of Bolt, dismissing the HMRC's appeal on all grounds, leading to a further appeal before the Court of Appeal. After examining both FTT's and UTT's decisions, as well as the Court of Justice of the European Union (ECJ) case law, the Court of Appeal overturned both previous decisions and ruled in favour of HMRC.

In doing so, the Court of Appeal held that Bolt's ride-hailing services do not qualify under TOMS, making clear that the company must pay GBP 190 million (approximately EUR 219 million) in outstanding VAT. The ruling also sets a critical precedent for the significantly larger dispute between HMRC and Uber, valued at GBP 1.4 billion (approximately EUR 1.62 billion). As a result of this decision, both Bolt and, by extension, Uber must apply a 20% VAT rate to the entire ride fare, not merely the margin.

Conclusion

Given the significance of both cases and the considerable practical and financial implications that follow, it is expected that Bolt will seek to challenge this decision through available legal remedies. It will be particularly interesting to see whether the FTT will follow the Court of Appeal's interpretation in the HMRC v. Uber proceedings, or whether it will await further developments in the Bolt appeal before doing so.