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HMRC internal manual

VAT Books

HM Revenue & Customs
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Books: What kinds of article are eligible?: Covers, cases and other articles (Item 6)

A small number of booksellers specialise in providing public libraries with books fitted with plastic dust-jackets, ticket-pockets and similar accessories. Invoices for these supplies normally show separate charges for books and for the fitting of the jackets and other items. In these limited circumstances, the fact that the accessories are separately accounted for will not preclude zero-rating. If the accessory is firmly fitted to the book itself so as to form an integral part of it, we view the resulting supply as a single supply of a zero-rated book, which may be zero-rated in its entirety.

Challenges to our interpretation

We view Item 6 as giving relief to incidental items which are supplied to accompany any one article of zero-rated printed matter. We do not accept that covers, cases etc includes:

  • covers which are a means of packaging a multiplicity of articles - for example, envelopes enclosing direct mail packs or children’s activity packs, or
  • printed folders into which other printed matter articles are inserted.

In the above instances, the cover is not incidental to any one article, but is a means of creating a package. Such packages may be dealt with in a number of ways. You will find details at section VBOOKS8000.

Odhams Leisure Group Ltd

The High Court decision in Odhams Leisure Group Ltd [1976] VATTR 229 supported the Tribunal decision that items within a children’s activity pack did not fall within Item 6 of Group 3. The appellant company argued that by placing some zero-rated articles within a cover (an outer envelope in this case), all articles of any liability within the cover could be viewed as other articles, and could thus benefit from zero-rating. The High Court confirmed that when referring to other articles, Item 6 only intended to relieve all sorts of packing and wrapping materials.