HMRC (Appellant) v Bolt Services UK Ltd (Respondent)
Tuesday 19 – Wednesday 20 May 2026
By Appellant’s Notice filed on 24 June 2025 the Appellant HMRC, seek to appeal a decision of the Upper Tribunal (Tax Chamber), delivered on 24 March 2025.
Bolt Services UK Ltd runs a ride‑hailing platform, buying PHV services from self‑employed drivers and selling them to customers via its app.
In February 2023, HMRC determined that Bolt’s services did not fall within the Tour Operators’ Margin Scheme (TOMS) for VAT purposes. Bolt appealed, and the First‑tier Tribunal (FTT) ruled in its favour. HMRC then appealed to the Upper Tribunal (UT), which upheld the FTT’s decision.
The Upper Tribunal considered whether Bolt’s services were of a kind commonly provided by tour operators or travel agents. It agreed with the FTT’s high‑level approach, holding that passenger transport is broadly the type of service supplied by tour operators.
The Tribunal also examined whether Bolt’s services were materially altered or constituted in‑house supplies. It rejected HMRC’s argument that the platform and licensing arrangements fundamentally changed the nature of the drivers’ services.
HMRC’s appeal was dismissed, with the Upper Tribunal finding no material error of law in the FTT’s reasoning.
Respondent’s Skeleton Argument
View Hearing:
Day 1