Reacting to: Bolt set for £190m VAT bill after legal defeat (City A.M., 8 October 2026) →
The Supreme Court has refused Bolt permission to appeal a Court of Appeal ruling that leaves it facing a VAT bill of up to £190 million. Bolt is the ride-hailing platform that, alongside Uber, lets passengers book private hire journeys through an app, taking a cut of each fare. The case turned on one question: does Bolt account for VAT on its own commission only, or on the full value of every fare passing through its app? HMRC said the full value. The Court of Appeal agreed with HMRC in June 2026, overturning an earlier tribunal decision that had gone Bolt's way, and on 8 October 2026 the Supreme Court refused permission to appeal that ruling, saying the case "does not raise an arguable point of law of general public importance." There is no further route through the UK courts.
A dispute about margin, not about Bolt specifically
Bolt's defence rested on the Tour Operators' Margin Scheme, known as TOMS — a VAT mechanism built for businesses that buy in and resell travel services, and set out in HMRC's own VAT Notice 709/5. Under TOMS, VAT is due only on the operator's margin: the gap between what the customer pays and what the supplier, in this case the driver, is paid. Sue Rathmell, VAT partner at the accountancy firm MHA, put the mechanics plainly: "Under TOMS, VAT is only payable on the operator's margin rather than the full value of the fare." HMRC's position was that Bolt isn't a disclosed agent passing a driver's own supply through to the passenger. It argued Bolt is itself supplying the transport, at the full fare, with the driver as its subcontractor — and on that reading, VAT is due on the whole fare, not the slice Bolt keeps. The Court of Appeal agreed with HMRC's reading of how the business actually operates.
The numbers behind the case show the scale a VAT basis gets tested against once a dispute like this reaches the courts. Bolt generated €2.27bn (£1.92bn) in revenue in 2025, the UK is its second-biggest market, and around 100,000 drivers earn through its platform here. Kimberly Hurd, Bolt's senior general manager for UK and Ireland, said: "Two courts have already found in Bolt's favour on this question. We are therefore disappointed that the Supreme Court has refused permission to appeal the Court of Appeal's findings," adding that "businesses need a tax framework that supports a competitive market," with consequences "for fares, for driver earnings and for consumer choice across the sector." Uber is reported to be facing a similar dispute over roughly £1bn of VAT on the same basic question, which has effectively been on hold pending Bolt's outcome.
What the same arithmetic looks like at a much smaller scale
None of Buzz's clients run a business anywhere near Bolt's size, but the mechanics behind this case apply at any scale. Any VAT-registered business accounting for VAT on a margin or commission, rather than on the full value of what passes through it, is using the same basic structure HMRC successfully challenged here. The figures below are an illustrative example only, built to show what that structure means in cash terms — they are not Bolt's own numbers, which Buzz has no access to beyond what has been reported.
Take an illustrative private hire booking platform with £600,000 of gross fares passing through its app over a year, keeping a 20% commission on each fare and paying the rest straight to its drivers. On a margin basis, VAT is due only on that commission. The commission is £120,000, and treating that as VAT-inclusive at the standard 20% rate, the VAT due works out to one-sixth of it: £20,000. If HMRC instead successfully argues, as it did against Bolt, that VAT is due on the full value of the fares rather than just the commission, the VAT due is one-sixth of the whole £600,000: £100,000. That's an £80,000 difference in a single year, on a platform a tiny fraction of Bolt's size. Because HMRC can typically go back up to four years when it successfully challenges a VAT treatment, the same gap repeated over four years is a backdated bill of up to £320,000, before any interest or penalty is added.
| Illustrative booking platform, £600,000 gross fares, 20% commission | Amount |
|---|---|
| VAT on commission only (margin basis) | £20,000 |
| VAT on full value of fares (HMRC's successful basis against Bolt) | £100,000 |
| Difference, one year | £80,000 |
| Same gap repeated over a typical four-year HMRC assessment | Up to £320,000 |
What it means depending on where you sit
If your business already operates on a margin or agency VAT basis — a private hire or courier booking platform, a letting or property management agent, an events or ticket resale business, or anything where you take a cut of a larger sum passing through your hands — this case is a direct prompt to have that treatment reviewed now, with the paperwork that supports it, rather than waiting for HMRC to open an inquiry of its own. The Court of Appeal's judgment turned on how the business actually operates in practice, not just on what its contracts say, so the evidence that backs up your VAT position matters as much as the position itself.
If you're VAT-registered on a standard basis and none of this applies to how you charge VAT, the wider lesson still holds: a VAT treatment that has worked for years, and that has already survived earlier hearings, as Bolt's had, can still be overturned on a later appeal, with the liability backdated rather than starting from the date of the ruling. It's worth treating any VAT position that depends on a judgement call, rather than a straightforward standard-rated sale, as something to get checked periodically rather than set once and left alone.
What to do this week
If any part of your business works on a margin, commission or agency VAT basis, read HMRC's own VAT Notice 709/5 on the Tour Operators' Margin Scheme against how your business actually operates, not just what your contracts or booking terms say, and get a second opinion if there's any doubt. We've written before about what a VAT return being wrong actually costs, once interest and penalties are added, and the same arithmetic applies here, just triggered by a treatment issue rather than a late filing. Getting a VAT basis checked properly, before HMRC asks the question itself, is exactly what our VAT returns and registration service is for.
What's still uncertain, and when we'll know
Whether Uber's roughly £1bn dispute now moves to a tribunal hearing, settles, or is argued on different facts to Bolt's has not been announced. Bolt has not said whether it will pass the additional VAT cost on to passengers or drivers, absorb it itself, or dispute HMRC's calculation of the £190m figure. Both are worth watching over the coming months, not assumed either way now.