Uber London Limited v The Commissioners for HMRC

Uber London Limited v The Commissioners for HMRC

The Tribunal granted HMRC’s application for an unconditional stay, finding that Uber’s appeal is being entertained as the Deposited Sums have been paid, there is no statutory basis for repayment during the stay, and the final determination of the Bolt Appeal will materially assist in resolving Uber’s appeal. The hardship provisions do not apply as no hardship claim was made, and fairness must operate within statutory bounds.

Parties
Appellant: Uber London Limited; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
31 October 2025
Procedural Posture
Tax Appeal / Application for Amendment to Stay Direction Pending Final Determination of Appeal in Other Case
Outcome
HMRC’s application for an unconditional stay granted.
Legal Topics
VAT Appeals, Tour Operators Margin Scheme (toms), Stay of Proceedings, Deposited Sums, Hardship Provisions
Tax Law Administrative Law VAT Appeals Tour Operators Margin Scheme (toms) Stay of Proceedings Deposited Sums Hardship Provisions

Case Brief

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Parties

Uber London Limited

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Application for Amendment to Stay Direction Pending Final Determination of Appeal in Other Case

Legal Issues

  1. 1 Whether Uber’s appeal should be stayed unconditionally pending the outcome of the Bolt Appeal
  2. 2 Whether the stay should be conditional on HMRC returning the Deposited Sums
  3. 3 Interpretation of 'entertained' in section 84(3) VAT Act 1994

Ratio Decidendi

The Tribunal granted HMRC’s application for an unconditional stay, finding that Uber’s appeal is being entertained as the Deposited Sums have been paid, there is no statutory basis for repayment during the stay, and the final determination of the Bolt Appeal will materially assist in resolving Uber’s appeal. The hardship provisions do not apply as no hardship claim was made, and fairness must operate within statutory bounds.

Court Disposition

HMRC’s application for an unconditional stay granted.

Orders

  • These appeals are stayed until 35 days after the appeal of HMRC v Bolt Services UK Limited is finally determined and all time limits are extended accordingly.
  • Any party may apply at any time for this direction to be amended, suspended or set aside.