Billionaire property developer and Reform UK treasurer Nick Candy significantly reduced the stamp duty payable on the sale of his Chelsea mansion through strategic structuring of the transaction, according to an investigation by independent tax analysts.

In May, Candy sold Providence House, a grade II listed property in west London, for a record £265 million. The sale was reportedly arranged so that five additional flats, valued at a few hundred thousand pounds each, were bundled with the main mansion. This strategy classified the transaction as a non-residential sale under HM Revenue & Customs (HMRC) rules, reducing the stamp duty rate from 12% to 5% for the buyer. Consequently, hedge fund manager Suneil Setiya paid £13.25 million in stamp duty rather than the £31.8 million that would have been due on a standard residential transaction.

Dan Neidle, head of the think tank Tax Policy Associates, noted that while legally the stamp duty savings belong to the buyer, in practice these savings often affect the price negotiated between the parties. He explained that a buyer facing a significantly lower tax bill may be willing to offer a higher purchase price, effectively sharing the benefit with the seller. Tim Stovold, head of tax at Moore Kingston Smith, an accountancy and advisory firm, emphasized that rules pertaining to sales of six or more dwellings were originally designed for landlords acquiring property portfolios. He pointed out that using this provision in a case where most of the sale value relates to a single property was unanticipated.

This transaction follows a previous dispute involving the Candy family and HMRC concerning stamp duty on Providence House. In 2012, Christian Candy purchased the property for £68 million, paying £1.92 million in stamp duty before transferring it to his brother Nick in 2014, who subsequently paid the remaining amount and a further £1.92 million in stamp duty. Christian Candy’s later application for a refund was initially rejected on grounds of late submission but was partially upheld by the Upper Tribunal earlier this year, resulting in a £2.3 million repayment with interest.

Under Nick Candy’s ownership, Providence House underwent extensive renovations, transforming it into a sprawling estate featuring a 14,000 square foot basement with amenities such as a 60-foot swimming pool and Europe’s first private IMAX cinema. Candy’s personal circumstances, including his separation from Australian actress and singer Holly Valance, who lived at the property, are believed to have influenced the decision to sell.

Setiya declined to comment on the transaction. Sources indicate that he maintains the view that the correct amount of stamp duty was paid in line with legal requirements and that the properties were made available and sold as a collective package. A spokesperson for Nick Candy stated that he is currently out of the country and will not be making any comments.