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Aim of arrangements

30 April 2018
Issue: 4645 / Categories: Tax cases

CRC v Paul Newey (trading as Ocean Finance), Court of Appeal, 17 April 2018

Offshore structure to save VAT
The taxpayer N provided services as a licensed credit broker in the UK. The business was not registered for VAT because it made exempt supplies only and as a result incurred irrecoverable VAT on advertising and other supplies.
So that the business could obtain advertising services VAT-free N set up a company (Alabaster) in Jersey. He transferred the loan broking business to Alabaster which outsourced the processing operations back to the UK. It then engaged an advertising agency in Jersey. The brokerage services were still made in the UK so remained exempt.
The advertising services were treated as not subject to UK VAT because the supplier of the services and Alabaster belonged in Jersey.
HMRC said N...

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