Big Tech’s Billion-Pound Tax Argument Refused — The Money Stays Public

Big Tech’s Billion-Pound Tax Argument Refused — The Money Stays Public

12 June 2026

In a courtroom in the Strand, a tax barrister named Eleni Mitrophanous KC stood up to defend the public purse. On Friday, she won.

The case was HMRC against Bolt, the ride-hailing firm. Bolt wanted to be taxed like a travel agent. Under a special rule meant for tour operators, it would have paid VAT only on its profit margin, not on the full fare. The saving to Bolt was put at around £190 million. Behind it sat other cases worth more than a billion pounds.

Twice already, the argument had succeeded. Two tribunals had sided with Bolt. By the time the case reached the Court of Appeal, the momentum was against HMRC.

Mitrophanous, leading for HMRC with Charlotte Brown, made the case plain. Travel agents and tour operators do not offer minicab rides. Bolt operates in the minicab sector, and an ordinary passenger would know it. To stretch the travel agents’ rule over Bolt’s business, she argued, would empty the words of the law of meaning.

The court agreed. Lady Justice Falk, giving the lead judgment, credited her submissions directly. Lord Justice Arnold and Sir Colin Birss, the Chancellor of the High Court, agreed with her.

The result holds the line. The VAT stays with the Treasury.

Source: HMRC v Bolt Services UK Limited [2026] EWCA Civ 720, Court of Appeal, 12 June 2026, paras 73–79.