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Heading
Case Number: UT/2024/000008
Rolls Building, 7 Rolls Buildings,
Fetter Lane, London, EC4A 1NL
VALUE ADDED TAX – Tour Operators’ Margin Scheme – mobile ride hailing services – whether services of a kind commonly provided by tour operators or travel agents – yes – whether services materially altered or further processed – no – appeal dismissed
and following written representations received on: 27 January 2025
Judgment date: 24 March 2025
Before
MR JUSTICE MEADE
JUDGE ASHLEY GREENBANK
Between
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Appellants
and
BOLT SERVICES UK LIMITED
Respondent
Representation:
For the Appellants: Eleni Mitrophanous KC and Charlotte Brown, counsel, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs
For the Respondent: Valentina Sloane KC and Jenn Lawrence, counsel, instructed by Deloitte LLP
DECISION
- Heading
- Introduction
- Scope of the appeal
- Relevant legislation
- Facts
- Mr Ryan’s evidence
- The FTT Decision
- The parties confirmed at the hearing before us that these items remained common ground between them
- The Grounds of Appeal
- Issue 1: services of a kind commonly provided by tour operators or travel agents
- The parties’ submissions in outline
- Discussion
- Principles derived from the CJEU case law
- Ground 1: the high-level approach
- Grounds 1a, 2 and 2a: the alternative reasons for the FTT’s conclusion
- Ground 3: multiplicity of supplies
- Conclusions