Bolt Services UK Ltd v HMRC

In Bolt Services UK Ltd v HMRC [2023] UKFTT 1043 (TC) (15 December 2023) the FTT held that the appellant’s on-demand ride-hailing services fell within the scope of the VAT Tour Operators Margin Scheme (TOMS).

The appellant (Bolt) operated an on-demand private hire passenger transport service. The service was ordered and paid for via a smartphone application. Bolt sought a non-statutory ruling from HMRC that the TOMS applied to the service and HMRC issued a decision that it did not. This decision was the subject of the appeal to the FTT.

Using the Bolt smartphone application customers could book private hire vehicles to take them from point A to point B. Bolt would accept requests for rides and provide customers with estimated fares and arrival times. Journeys would be allocated to private hire vehicle drivers. These drivers were independent contractors. Bolt contracted separately with the drivers and the passengers and...

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