QBD 6 November 1987. In 1983 Faith Construction (F) began negotiations with another company (D) for substantial alterations to be carried out on a property owned by D, the cost being agreed at £300,000 on the basis that the goods and services would be zero-rated for VAT by virtue of Value Added Tax Act 1983 . In the Finance Act 1984 s10 alteration work became standard-rated as from 1 June 1984, the supply to be treated as taking place when the person making the supply received payment. The two companies sought to take advantage of this by a complex series of loans involving payment in full before the date and a series of repayments. The Commissioners assessed F for VAT on instalments paid after 1 June 1984. F applied to a VAT tribunal which upheld their case. The Crown appealed and it was held that the transactions were genuine and constituted a single transaction, that the steps inserted into it had no commercial purpose other than to avoid liability to tax and therefore the instalm