UT/2024/000008 - [2025] UKUT 00100 (TCC)

This is an appeal by the appellants, the Commissioners for His Majesty’s Revenue and Customs (“HMRC”), against a decision of the First-tier Tribunal (the “FTT”) dated 15 December 2023 (the “FTT Decision”) (Footnote: ¹).

In the FTT Decision, the FTT allowed the appeal of the respondent, Bolt Services UK Limited (“Bolt”) against a decision of HMRC contained in a letter dated 28 February 2023 that certain mobile ride-hailing services provided by Bolt as principal did not fall within the Tour Operators’ Margin Scheme (“TOMS”) for the purposes of Value Added Tax (“VAT”).

HMRC appeals against the FTT Decision with the permission of the FTT.

At the hearing, HMRC were represented by Eleni Mitrophanous KC and Ms Charlotte Brown. Bolt were represented by Valentina Sloane KC and Ms Jenn Lawrence. We are grateful to counsel for their helpful submissions, both orally and in writing, and for their assistance during the hearing.

Following the hearing, the Upper Tribunal released its decision in HMRC v Sonder Europe Ltd [2025] UKUT 14 (TCC) (“Sonder UT”). We requested representations from the parties on the potential implications of the Upper Tribunal’s decision for this appeal. Those representations were received on 27 January 2025 and we have taken those representations into account in this decision.