Leadership1 publisherNot yet confirmed elsewhere2 min readPublished
Supreme Court refusal leaves Bolt with an estimated £190m UK VAT bill
Bolt faces an estimated £190m in unpaid UK VAT after the Supreme Court refused to hear its appeal over the tour operators' margin scheme. Uber's £1bn dispute over the same scheme had been waiting on Bolt's case, so the refusal reaches past one company's bill.
The Board Room · Leadership desk
What happened
- HMRC had argued since February 2023 that Bolt did not qualify for the margin scheme, and the Court of Appeal backed that position.
- Under the scheme, Bolt accounted for VAT only on the commission it takes, leaving out the rest of the gross fare the passenger pays.
- The Supreme Court said the case raised no arguable point of law of general public importance that it ought to hear at this time.
- Black cab drivers wrote to the Chancellor last November asking that ride-hailing apps pay the same level of VAT as cabbies.
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Why it matters
- constraint With permission refused, Bolt's remaining choices on this question are commercial: how to fund the bill and how to price UK rides from here.
- cost A cost near a tenth of a year's group revenue has to come out of passenger fares, driver earnings or Bolt's margin in its second-biggest market.
- precedent Uber's dispute, five times larger, now goes to the Tax Tribunal with a standing Court of Appeal judgment that HMRC can point to.
Bolt's objection to the outcome rests on a count of courts. "Two courts have already found in Bolt's favour on this question," Kimberly Hurd, Bolt's senior general manager for the UK and Ireland, said [7]. Those were the decisions the Court of Appeal overturned in June [2]. Sue Rathmell, VAT partner at MHA, said: "The Supreme Court's decision to refuse Bolt permission to appeal means HMRC's victory at the Court of Appeal now stands" [15].
The bill is large next to the business that has to pay it. HMRC's claim is an estimated £190m in unpaid VAT [4]. Bolt's 2025 revenue was €2.27bn, which City AM put at £1.92bn [9], so the bill is about a tenth of a full year's group revenue [19]. The UK is Bolt's second-biggest market [10]. The report does not say which years the £190m covers or whether Bolt has set money aside for it.
Taxing the whole fare instead of the commission leaves Bolt with one question to settle: who carries the extra VAT. Passengers, drivers and Bolt's own margin are the only places it can land. Hurd named the first two. "This has consequences for fares, for driver earnings and for consumer choice across the sector that earlier rulings provided," she said [8], and she pointed to "the 100,000 drivers that earn through our platform" [18].
Uber carries the larger exposure. It is contesting a £1bn VAT bill over the same scheme and is waiting for the Tax Tribunal to hear it [13]. That is a little over five times Bolt's figure [20]. The Court of Appeal's June judgment said other cases, including Uber's, were awaiting the outcome of Bolt's case [14]. "Uber's case was effectively waiting in the wings behind Bolt, so this decision is likely to bring the wider litigation to a close," Rathmell said [16].
For the rest of the sector, the record supports a firm expectation but not a final answer. Rathmell's word is "likely", and Uber's case has still to be heard [13]. In Rathmell's account, HMRC's position for several years has been that "the scheme was never intended to apply to ride-hailing businesses" [12]. In my view, a UK platform built on commission-only VAT should plan on VAT across the gross fare from this quarter. Whatever it chooses now, between higher fares, lower driver pay and a thinner margin, is the choice Uber's tribunal result will either confirm or reopen.
What to watch
- Uber's Tax Tribunal hearing on its £1bn margin-scheme bill, and whether the tribunal follows the Court of Appeal's Bolt judgment.
- Whether Bolt changes UK fares or driver pay, and what period and payment schedule the £190m turns out to cover.
- Any public response from HMRC or the Treasury, including to the black cab drivers' letter to the Chancellor.
Clarity's read
What the record supports and how the coverage leans. The claims behind it follow.
Reality
- Evidence58
- Adoption
- Insufficient
- Hype gap+12
- Incentives62
- Confidence60
Claim ledger
Ranked by verification strength, evidence, and original report placement.
- [1]
The Supreme Court refused Bolt permission to appeal in a case brought by HMRC over how Bolt calculates and pays its VAT.
- [2]
HMRC won an appeal at the Court of Appeal in June against Bolt over its VAT payments and calculations, overturning earlier decisions that had ruled in Bolt's favour.
- [3]
Under the tour operators' margin scheme (TOMS), businesses pay VAT only on the profit margin between buying a service and selling it; by qualifying, Bolt accounts for VAT only on the commission it takes from the fare, rather than the entire gross fare paid by the passenger.
- [4]
Bolt's appeal involves an estimated £190m in unpaid VAT.
- [5]
HMRC argued in February 2023 that Bolt did not qualify for TOMS, and the Court of Appeal backed the tax authority's decision.
- [6]
The Supreme Court said Bolt's application "does not raise an arguable point of law of general public importance which the Supreme Court ought to hear at this time."
- [7]
"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." - Kimberly Hurd, senior general manager for the UK and Ireland at Bolt.
- [8]
"This has consequences for fares, for driver earnings and for consumer choice across the sector that earlier rulings provided" - Kimberly Hurd, Bolt.
- [9]
Bolt generated €2.27bn (£1.92bn) in revenue in 2025.
- [11]
Sue Rathmell, VAT partner at MHA, said the decision "brings to an end a long-running dispute."
- [12]
"HMRC has argued for several years that the scheme was never intended to apply to ride-hailing businesses, while operators maintained that they were entitled to use it under the existing legislation" - Sue Rathmell, MHA.
- [13]
Uber has a similar ongoing legal battle over a £1bn VAT bill over TOMS, awaiting a hearing at the Tax Tribunal.
- [14]
The Court of Appeal said in its June judgment that other cases, including Uber's, "are awaiting its [Bolt's case's] outcome."
- [15]
"The Supreme Court's decision to refuse Bolt permission to appeal means HMRC's victory at the Court of Appeal now stands" - Sue Rathmell, MHA.
- [16]
"Uber's case was effectively waiting in the wings behind Bolt, so this decision is likely to bring the wider litigation to a close" - Sue Rathmell, MHA.
- [17]
Black cab drivers wrote to the Chancellor last November asking her to make the ride-hailing apps pay the same level of VAT as cabbies.
- [18]
Hurd's statement referred to "the 100,000 drivers that earn through our platform".
- [19]
Bolt's estimated £190m VAT bill is about a tenth (roughly 9.9%) of its 2025 group revenue of £1.92bn.
- [20]
Uber's £1bn disputed VAT bill is a little over five times Bolt's estimated £190m.
Sources
1 independent publisher whose own reporting we read for this story.
- cityam.comBolt set for £190m VAT bill after legal defeat
1 article · October 8, 2026
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