Digital Platforms, VAT, and our reporting requirements

We operate software that may meet the definition of a Platform, but no Reportable Sellers arise. So there’s nothing for us to collect or report.

Why

Everything on the site is one of two things.

1. Listings and adverts, where any deal happens away from the site. We provide no payment method for these. People list their own payment methods (SEPA, CashApp, gifting platforms, bank transfer, Wise, whatever works for them). A buyer might email a seller: “I see you’re selling a St Andrews Cross for £400. How about £300 and I collect this weekend?” Prices on the site are guide prices only. The same applies to services: someone may show an example rate for a custom video or video call, but agreeing the details and payment happens off-site. We have no knowledge of the final price, and our system never records a sale or an agreed price.

2. Pre-recorded content, which is not a Relevant Activity. This covers one-off purchases, Subscriptions (access to pre-made content), and Fan memberships (discounted access to pre-made content).

VAT

We charge VAT to Creators on our own fees as and when required, (currently we are NOT VAT registered as below the threshold). 

We do not add VAT to content sales, because the Creator is the supplier. We host the content and follow their instructions.

 

How an off-site sale works

  • The buyer pays the Creator directly, using one of the Creator’s own payment methods.
  • We are not involved in the sale and do not see or record the price. For example, a buyer may negotiate a discount (“$200 for 12 months is too much, can you do $150?”), or the Creator may post on X, “Flash Sale! 12 months, usually $200, today just $150. Pay me via X Money.” None of this passes through our site.
  • The Creator logs in and manually grants the buyer access to the content.

How a Lightning sale works:

  • The buyer presses the Buy button.
  • Our site asks the Creator’s own Lightning service for an invoice. That service has nothing to do with us.
  • The Creator’s service (usually an LUD-21 or NIP-57 enabled bitcoin wallet) generates the invoice, and it’s shown to the buyer.
  • The buyer’s wallet pays the Creator’s service directly. We never hold the funds.
  • When the Creator’s own Lightning service confirms it has been paid, the site unlocks the content. Unlocking is the only thing a confirmed payment can trigger; the site makes no other decision and has no discretion over it.
  • We email the Creator a record of the unlock.

In addition:

  • Creators set their own prices, with no platform minimum.
  • Creators set their own refund and licence terms.
  • The invoice or zap receipt identifies the Creator as the seller.
  • Our T&Cs govern use of the site only, not purchases.
  • We take no commission on sales. We charge membership and usage-based Cloud fees instead.

What would change this

Any of the following could make us a Reporting Platform, meaning we’d have to collect, hold and share your data. That’s why, if you ask for them, the answer is “sorry, not possible for tax-compliance reasons”:

  • Buy buttons for anything other than pre-recorded content, Subscriptions or Fan memberships.
  • Tip or Donation buttons, because too high a risk of, "Tip Me $X and I'll send you a little custom video". Facilitating custom videos would bring the Platform into scope and trigger reporting requirements. 
  • A commission on sales.
  • Recording agreed prices or sales on the site for anything other than content, including through on-site messaging.
  • Holding or escrowing funds, or offering custodial wallets.
  • Setting the contract terms between Creator and buyer.

 

HMRC Tax Manual