Nick Candy and Holly Valance. Britain’s most expensive house. A £265m sale. Usual consequence: £32m of stamp duty. But…

Nick Candy and Holly Valance. Britain’s most expensive house. A £265m sale. Usual consequence: £32m of stamp duty. But five small flats were included in the sale. By an extraordinary happy accident, that cut the tax by £18.5m. The curious sale of Nick Candy’s mansion A 🧵:

Our full report is here with all the technical details: taxpolicy.org.uk/2026/09/21/nic… Our investigation was in conjunction with London Centric, who originally spotted the point. Their report is here: londoncentric.media/p/londons-most…

Nick Candy acquired Providence House in 2014. It's a Grade II listed villa built in 1809 to a design by Thomas Leverton, and has the largest private garden in central London outside Buckingham Palace historicengland.org.uk/listing/the-li…

In 2024 Mr Candy sold it to a limited liability partnership mostly owned by him and his wife, Holly Valance. We're not sure why, but probably to enable him to extract £140m from new bank financing.

It was reported in April this year that Mr Candy sold the house for £265m to Suneil Setiya, a hedge fund manager. Making it the most expensive house ever sold in Britain. (Politics: Candy is Reform UK Treasurer. Setiya is a major Labour Party donor.)

How much stamp duty/SDLT was due? That depends.

If Providence House LLP had sold Providence House to Mr Setiya for £265m and it had been treated as *residential* property, Mr Setiya would have faced a stamp duty bill of about £32m

If, alternatively, Providence House had been treated as *commercial property*, the answer would have been very different. The top commercial rate is only 5%, so the bill would "only" have been about £13m.

One might expect the answer to be obvious. Providence House is residential, because it's a house that people live in. It is, quite literally, a residence.

But here the obvious answer is wrong, because Mr Candy's LLP also owned five small properties, around £2m altogether, two of them bought in the thirteen months before the sale. Why does that matter? Because s116(7) Finance Act 2003

Section 116(7) Finance Act 2003 says: This is the 6+ rule. If you buy six or more dwellings, then it’s treated as a purchase of non-residential property. 5% stamp duty.

Here it makes an enormous difference. Most obviously it takes the rate down from 12% to 5%. But there are also no surcharges, so it wouldn't matter if Mr Setiya were non-resident or buying a second home. The rate stays at 5% either way.

So including the five flats in the sale saved £18.5m of stamp duty. Stamp duty is paid by the buyer. So as a matter of law every penny of the saving belongs to the buyer, Mr Setiya.

That often isn't the economic answer. A buyer facing £32m of stamp duty will bid less for a house than a buyer facing £13m. The saving gets shared through the price (one way or another). So Mr Setiya probably shared the benefit.

So Messrs Candy and Setiya certainly avoided £18.5m of tax. Was it "tax avoidance" in the usual meaning of the term? That's a question of fact and degree. It is also not the relevant legal question..

There's a specific stamp duty anti-avoidance rule, in section 75A of the Finance Act 2003. Funny thing about s75A is it doesn't care about your motive/intention. It just looks at if you did something that saves tax.

So the question of whether this was "tax avoidance" is more of a moral (and perhaps political) question than a question of tax law. Our view - although others may well disagree - is that there is a spectrum:

1. At one end is a "happy accident" - you buy six properties and have no idea that will save you stamp duty, but it does. Accidents tend not to happen in £265m transactions. So maybe you nudge things towards that result

2. At the other end artificial: you're planning to buy/sell one property, but shoehorn in five, so you can claim the six-plus property rule.

It's possible we are in the first scenario - that there was careful planning, but this was not an artificial scheme. A very wealthy person acquiring a large property does sometimes acquire additional nearby properties as accommodation for staff.

But the timing is curious: two of the flats were bought in the thirteen months before the sale, on expensive short-term finance. And the buying stopped at exactly six dwellings, which is of course the number the 6+ rule requires.

Looking at the available facts, it was the view of most (but not all) of the stamp duty experts we spoke to that this looked like an artificially designed structure. But we don't know for sure. Neither party would comment on the record.

But whether it was artificial or not, this is far from clear. The existing tax anti-avoidance rules can apply here. If this is a loophole, it's a very rare example of a loophole that works. (lots of detail on this in our report)

If HMRC can't or won't challenge, or if a challenge fails, the government should close the loophole and change the law. Otherwise, we're going to see lots of high-end properties being sold with five teeny flats.

We've got more tax investigations coming soon, including a shocking and unethical structure that's trying to rip off thousands of people for hundreds of millions of pounds. To be sure to catch it, you can subscribe for free here: taxpolicy.org.uk/subscribe/?utm…