The publisher, owned by Rupert Murdoch, argued that the digital editions of newspapers, including the Sunday Times, daily Times, the Sun and Sun on Sunday, should have been zero-rated in the same way as print editions.

On 22 February 2023, the Court ruled that digital editions of newspapers were not eligible for the VAT zero-rating exemption given to print editions, over a six-year period from 30 August 2010 and 4 December 2016. From May 2020 the rules were changed to introduce zero rating to digital editions.

News Corp argued that its digital newspaper editions should have been treated like the print versions which are zero-rated for VAT.