Minerva Research Labs Limited v The Commissioners for HMRC
Decision date: 14 September 2026
Neutral citation: [2026] UKFTT 1320 (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 appeal concerned whether 18 collagen‑based liquid "Products" sold by Minerva were zero‑rated as "food of a kind used for human consumption" for VAT purposes. The Tribunal applied a multi‑factorial test, giving significant weight to how the Products were held out for sale and the consumers' purpose (cosmetic/anti‑ageing dosing regimens, pharmacy sales, warnings), and concluded those factors outweighed nutritional characteristics. The Tribunal refused the appeal and upheld HMRC's decision that the Products are standard‑rated.
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's ratio is that, in determining zero‑rating under Item 1, Group 1, Schedule 8 VATA, a multi‑factorial assessment is required and the manner in which a product is held out for sale and the purpose for which it is purchased are material factors that can carry significant weight; nutritional content or regulatory labels alone do not determine food status.
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 that dictionary definitions add little beyond ordinary understanding and have limited utility in zero‑rating disputes, and it declined to admit a late Brexit/standstill submission on procedural fairness grounds, leaving that novel point for any appeal rather than deciding it.