Bolt VAT appeal refused by Supreme Court over £190m bill

Bolt’s VAT appeal has failed at the Supreme Court, leaving the ride-hailing firm facing an estimated £190m in unpaid VAT, according to City AM. The court refused permission to appeal on 8 October 2026, saying the application “does not raise an arguable point of law of general public importance which the Supreme Court ought to hear at this time.”

The decision most directly affects Bolt, which says 100,000 drivers earn through its platform. It also matters to passengers, if fares change, and to Uber, which has a similar dispute with HMRC. Bolt generated €2.27bn (£1.92bn) in revenue in 2025, and the UK is its second-biggest market, City AM reported.

Bolt ride-hailing VAT ruling: how the case reached this point

HMRC brought the case to test whether Bolt could use the Tour Operators’ Margin Scheme, known as TOMS. Under it, a business pays VAT only on the margin between what it buys a service for and what it sells it for, rather than on the whole fare. According to vatcalc.com, the First-tier Tribunal backed Bolt in December 2023 and the Upper Tribunal rejected HMRC’s appeal on 24 March 2025.

The government’s own policy paper confirms the Upper Tribunal ruling, HMRC v Bolt [2025] UKUT 00100, and says HMRC was then granted permission to appeal to the Court of Appeal. Vatcalc.com reports that on 12 June 2026 the Court of Appeal held that Bolt’s supplies were not services of a kind commonly provided by tour operators or travel agents.

Kimberly Hurd, Bolt’s senior general manager for the UK and Ireland, said in a statement: “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.”

What the VAT margin scheme means for fares

The difference between the two treatments can be large. Take an illustrative £30 fare that includes VAT, of which a platform keeps £6 as commission. These numbers are our own and are not Bolt’s. Under TOMS, VAT is due on the £6 margin only, which is £1.00. At the standard 20% rate on the whole fare, VAT is £5.00, a difference of £4.00 on that single journey.

Vatcalc.com says the ruling means Bolt must now charge 20% VAT on the entire fare. Who bears that cost is not settled by the sources. Hurd said the outcome has “consequences for fares, for driver earnings and for consumer choice across the sector”.

The government’s policy paper says passengers may be affected if operators change their fares. It adds that disabled people, who took an estimated 12.2 taxi or private hire trips per person in 2024 against 8.5 for those without a disability, and women aged 17-29 may be overrepresented among those affected.

Bolt Supreme Court VAT decision: what happens next for Uber

Uber is the obvious next question. City AM reports that Uber has a similar legal battle over a VAT bill of about £1bn, awaiting a hearing at the Tax Tribunal. Vatcalc.com puts the case at £951m and says Uber has made a provision of £386m in its latest financial statements. The Court of Appeal noted in June that other cases, including Uber’s, “are awaiting” Bolt’s outcome, according to City AM.

Sue Rathmell, VAT partner at MHA, said the refusal means “HMRC’s victory at the Court of Appeal now stands”. She added: “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 sources do not say whether HMRC plans action against other platform businesses, and City AM said HMRC was contacted for comment.

Separately, the government announced a change in the law at Budget 2025. From 2 January 2026, taxi and private hire journeys are due to be excluded from TOMS unless supplied with other travel services. The policy paper says this “ring-fences the litigation to past VAT periods”. HMRC’s costings for that measure, certified by the Office for Budget Responsibility, are below. The paper does not link them to the Bolt bill.