Court of Appeal overturns TOMS decisions on ride-hailing – Bolt Services

Summary 

• The Court of Appeal ruled that ride-hailing services do not fall within TOMS.
• HMRC’s appeal was upheld, reversing earlier tribunal decisions.
• The judgment restricts TOMS to services comparable to traditional travel operators.

Article

In HMRC v Bolt Services UK Limited [2026] EWCA Civ 720, the Court of Appeal held that ride-hailing services are outside the scope of the Tour Operators’ Margin Scheme (TOMS).

The Court rejected earlier rulings that extended TOMS to Bolt’s services, emphasizing that the scheme applies only to services that are identical or comparable to those typically supplied by travel agents or tour operators.

Since ride-hailing services are standalone transport services and not part of traditional travel packages, they cannot benefit from margin scheme treatment.

This decision has significant financial implications, as VAT must be applied to the full fare rather than the margin.

External links:

• Judgment: HMRC v Bolt Services UK Ltd
• Commentary: Deeks – VAT impact analysis