This was an appeal to the Upper Tribunal against a decision of the FFT that had found in favour of the Appellant. The appeal concerns the effect for VAT purposes of a scheme designed to obtain a tax advantage. It involves the creation of a company in Jersey (Alabaster) to which the Respondent (“Mr Newey”), who traded as Ocean Finance, transferred a loan broking business previously carried on by him in the UK. His position was that after the transfer it was Alabaster, rather than he himself, which made supplies of loan brokerage services to various UK lenders and that it was those companies, rather than Mr Newey himself, which received supplies of advertising services free of VAT. The questions in the appeal before the First-tier Tribunal were: