|Nicey replies: Dear Mr Two Lunches,
Its not a Biscuit, niether is it a cake, it is however the sort of thing that is often seen sharing a shelf with the equally troublesome flapjacks in our local bakery. The Kiwis make a lot of this type of thing, and maybe that has something to do with the Scots that emigrated there. They call them 'tray bakes' I believe. Whilst for us it shouldn't be too much of an issue if something takes up an unusual spot on the great venn diagram of biscuits, cakes and related items, for the VAT man its a big issue. The VAT man would probably see this as a biscuit that way he could tax it due to its chocolate being largely external.
I fear I haven't answered your question, never mind.