Uber London Limited v The Commissioners for HMRC
Decision date: 28 October 2025
Neutral citation: [2025] UKFTT 1282 (TC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
This case concerns HMRC's application to continue an unconditional stay of Uber London Limited's 2023 VAT appeal while the related Bolt litigation is finally determined and whether Uber should have its £1.446 billion deposited sums returned or the stay made conditional on repayment. The First-tier Tribunal continued the stay until 35 days after final determination of the Bolt Appeal (and related appeals), rejected Uber's request for repayment or conditional stay, and accepted that simple interest would be an appropriate remedy if repayment is later required.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: high
The Tribunal held that payment of the statutory deposit under the VAT Act is the active step by which an appeal is "entertained" for statutory purposes, so a subsequent stay does not negate that status, and the FTT lacks statutory power to order return of deposits as a conditional term of a case-management stay absent the statutory hardship mechanism being invoked at the relevant time.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The Tribunal observed (non-bindingly) that decision-makers must balance access to justice against protection of the revenue, that statutory interest may be an appropriate post-hoc remedy if deposited sums are later required to be repaid, and that HMRC's present decision not to enforce future assessments does not retrospectively require repayment of previously deposited sums.