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

The decision of HMRC which forms the subject matter of this appeal came in response to a request from Bolt in a letter dated 4 October 2022 for a non-statutory ruling in relation to the VAT treatment of mobile ride-hailing services. The services which were the subject of that request were on-demand, private hire passenger transport services provided by Bolt as principal, ordered and paid for through a smartphone application.

As noted at FTT [7] and [8], Bolt also provides other services, including scheduled rides that can be booked in advance. However, the request for the ruling and HMRC’s response were limited to Bolt’s on-demand services. On that basis, the FTT restricted its decision to the treatment of on-demand services. In reaching its decision, however, the FTT considered it appropriate to consider whether the supplies made by a private hire vehicle operator acting as principal more generally fall within the TOMS. We adopt the same approach.