The case involved the offshoring of a loan intermediation business to Jersey. The taxpayer, who remained in the UK, provided a processing service to Alabaster, the Jersey company he had set up, Alabaster then provided the intermediation services to UK lenders that the taxpayer had previously provided. This restructuring resulted in advertising services (supplied by a Jersey supplier) becoming outside of the scope of UK VAT because they were supplied to Alabaster. If VAT had been charged it would be irrecoverable.
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