The contract with your passenger is a tax position. Outside London, in England and Wales, it is still your choice.

In June the Court of Appeal decided a VAT case about mini-cabs. The sums say it was not a small one: the court was told Bolt’s appeal “involves an estimated £190m”, and that other cases “well in excess of £1bn” were waiting on the outcome. On 29 September the Supreme Court refused Bolt permission to appeal, on the ground that the application raised no arguable point of law of general public importance it ought to hear at this time. That is the end of the road.

What the case was about is worth an operator’s afternoon, because it is not really about tax.

One sentence in the judgment

Paragraph 10 describes how Bolt is assembled. It “contracts with drivers for their services and, separately, with customers, who have no contractual relationship with the drivers”.

Read that twice. Not the app, not the commission, not the ratings: the passenger and the driver are strangers to one another in law. The platform stands between them as the only party either of them has a contract with.

The judgment also says when that started. Bolt has, it records, “for regulatory reasons, acted as principal” since August 2022. It does not say which regulation, and we should not pretend otherwise: the timing points at the Administrative Court’s decision of 6 December 2021, which held that an operator licensed under the 1998 London Act must contract with the passenger as principal, but that connection is our reading and not the court’s. What is certain either way is that the shape was adopted to satisfy a regulator, not to win customers.

What being principal costs

The Treasury sets out the arithmetic plainly in its November 2025 response on private hire VAT. An operator acting as agent brings customer and driver together, the driver is making the supply, and the operator charges VAT on its agency fee alone. An operator acting as principal is making the supply itself, and charges VAT on the full fare the customer pays.

So a licensing answer turned into a tax bill. Several operators, Bolt among them, then reached for the Tour Operators’ Margin Scheme, which taxes a margin instead of a sale. The Treasury’s estimate of what that would have achieved is the number to remember: an effective rate of “around 4% instead of 20%”.

The Court of Appeal was not persuaded. The scheme “does not apply to Bolt’s on-demand mini-cab services”, because those services are “neither identical nor relevantly comparable” to what travel agents sell, and because travel agents and tour operators “do not compete in the provision of mini-cab rides”.

Parliament had already shut the door from the other side. Section 82 of the Finance Act 2026 adds a subsection to the Value Added Tax Act 1994: a person is not a tour operator so far as their business consists of carrying passengers by private hire vehicle or taxi, unless those journeys are supplied with, and are ancillary to, accommodation or travel by bus, coach, train, ship or aircraft. It bites on supplies made on or after 2 January 2026.

Outside London, in England and Wales, you still get to choose

This is the part worth getting exactly right, because half of it was undone and the other half was not.

Two judgments said operators should contract with passengers as principal. R (United Trade Action Group) v Transport for London, decided on 6 December 2021, said it for operators licensed in London under the 1998 Act. Uber Britannia v Sefton, in July 2023, said it for everybody else. The second did not survive: the Court of Appeal overturned it in July 2024, and on 29 July 2025 the Supreme Court upheld that reversal in D.E.L.T.A. Merseyside v Uber Britannia, holding that the 1976 Act does not require an operator to contract as principal.

The Treasury records what is left. The requirement stayed in place for operators licensed in London, and the judgment meant that “other PHVOs in England and Wales could act as agents”.

So if you are licensed in London the question is settled for you. If you are licensed elsewhere in England and Wales it is not, and your contractual model is still yours to pick. Scotland and Northern Ireland license under their own statutes, and none of this reaches them. What your accountant makes of any of it is their trade and not ours.

What the choice is actually about

Here is why this belongs in a journal about dispatch rather than in a tax newsletter.

Ask whose customer the passenger is, and the answer arrives from the same document as the VAT answer. If you are the principal, the passenger is yours and the driver is your supplier. If you are the agent, the passenger is the driver’s, and you are paid for putting the two together.

The Treasury asked the trade and wrote down what it heard. Many operators, it reports, still consider drivers to be the principal supplier of the service; some have maintained their previous contractual arrangements, while others have altered theirs in response to the judgments. Three answers in one trade, which means a fair number of operators would have to go and read their own paperwork to find out which one they are.

Where we come in, and where we do not

UrbanGo is not a party to that contract, in either direction. We do not buy rides and we do not sell them. We are the software an operator runs on, and the contractual model stays the operator’s to choose and the operator’s to change.

The bridge from that contract to us is narrower than it may look, and it is worth stating rather than implying. Whichever side of the principal question you land on, the contract names a counterparty, and a counterparty you cannot identify is not much of one. An operator contracting as principal needs to know who its customers are because they are its customers. An operator acting as agent needs the same list to show what it brokered and for whom. Neither position survives a shoebox of call logs.

So the record is the part we answer for. Every job that goes through the operator, including the ones that arrive by telephone, lands in a customer list with a name, a number and a history. That list exports in a format any other system can read, whenever you want it, without asking us and without explaining why.

Because the lesson of this case is not that one model beats the other. It is that Bolt’s contractual shape was settled by a licensing problem in 2022, and was still deciding its tax position four years later. These things get set once, quietly, by somebody solving a different problem. Then they hold for a very long time.