UK Supreme Court Refuses Bolt Permission to Appeal in TOMS Case

Summary 

• The UK Supreme Court refused permission in Bolt Services UK Ltd v HMRC, UKSC/2026/0096, because the application did not raise an arguable point of law of general public importance. 
• The Court of Appeal conclusion remains in force: Bolt’s on-demand private-hire services are not sufficiently comparable to services of travel agents or tour operators to fall within TOMS. 
• For the periods in dispute, ordinary VAT treatment therefore applies rather than taxation only on the TOMS margin; separate legislation has excluded most taxi and private-hire journeys from TOMS since 2 January 2026. 

Extended article 

Bolt had succeeded before the First-tier Tribunal and Upper Tribunal, but HMRC prevailed in the Court of Appeal. The Supreme Court’s refusal ends the litigation and leaves the Court of Appeal judgment as the leading authority for the earlier periods. 

The case turns on Bolt acting as principal in the resale of passenger transport. The distinction between principal and disclosed-agent models remains central because it affects whether VAT is accounted for on the full fare or on a commission. 

Source 

• UK Supreme Court: Bolt Services UK Ltd v HMRC 
• Crowe: Bolt VAT Ruling 
• VATupdate: Supreme Court Rejects Bolt Appeal 

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