Story Terrace Limited v The Commissioners for HMRC
Decision date: 11 December 2025
Neutral citation: [2025] UKFTT 1554 (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 Story Terrace's bespoke service producing four-colour hardback books (with digital copies) was a zero-rated supply of "books" or a standard-rated supply of ghost-writing services. The Tribunal found the contract and final outputs were books and, applying the predominance test from the viewpoint of the typical consumer, the provision of the physical book was the predominant element. The appeal was allowed and the supplies were held to be zero-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
Where a written contract governs a composite supply, the contract is the natural starting point for characterisation, but the predominant element must be identified by reference to the typical consumer’s overall assessment of the qualitative and quantitative importance of the components; a bespoke or customised element does not automatically render the supply standard-rated if the typical consumer’s economic purpose is to receive the physical book.
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 (not as binding authority) that post-IP completion day CJEU decisions are not binding and should be treated cautiously under EUWA; it also noted that it was appropriate not to draw an adverse inference from the absence of evidence from contracted ghost-writers when the relevant test is the objective view of the typical consumer.