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The FTT Decision
The FTT Decision
Having set out the facts, reviewed the relevant CJEU and UK authorities and concluded that the provisions of section 53 VATA and the TOMS Order can be interpreted in a way that is consistent with Articles 306 to 310 of the PVD, the FTT turned to its consideration of the relevant issues.
At FTT [103], the FTT set out the following matters that were common ground and so not in dispute between the parties:
Bolt was not a travel agent or tour operator within the normal meaning of those terms;
Bolt's passengers were travellers for the purposes of the TOMS;
Bolt's ride-hailing services were supplied for the benefit of travellers;
Bolt had a business establishment in the UK;
Bolt supplied the ride-hailing services as principal; and
the drivers’ services were acquired by Bolt for the purposes of its business.
- 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