C & E Commissioners v Mirror Group Plc

CJEC C-409/98; [2001] STC 1453; [2002] 2 WLR 288

The Mirror Group Plc (Mirror) received a reverse premium for entering into a new lease. The Mirror argued that the reverse premium was in relation to exempt activities of letting or leasing of immovable property. However, the ECJ held although the taking the lease is closely connected to the lease, the exemption must be strictly applies. As this transaction is not specifically included with the exemption and as Mirror did not have the property before the transaction it was decided to be a taxable supply.