The sale of Nick Candy’s £265m Chelsea mansion was structured so that the buyer paid £18.5m less in stamp duty, according to an investigation by the think tank Tax Policy Associates and the news website London Centric.
The research found that Candy, the billionaire property developer and Reform UK treasurer, included five flats “worth a few hundred thousand pounds each” in the sale of the grade II listed Providence House in May.
Where six or more dwellings are bought in a single transaction, HMRC treats the purchase as non-residential, and the top rate of stamp duty paid by the buyer falls from 12 per cent to 5 per cent. This is set out in government guidance on non-residential rates.
According to the investigation, Suneil Setiya, the City hedge fund manager who bought the mansion, paid £13.25m in stamp duty instead of £31.8m.
Dan Neidle, head of Tax Policy Associates, said bundling six properties in this way could benefit both buyer and seller, because money saved on stamp duty by the buyer would typically be informally added to the seller’s asking price.
“Stamp duty is paid by the buyer. So as a matter of law every penny of the saving belongs to the buyer, Mr Setiya,” Neidle wrote. “That often isn’t the economic answer. A buyer facing £32 million of stamp duty will bid less for a house than a buyer facing £13 million. The saving gets shared through the price one way or another.”
The Tax Policy Associates report, published yesterday, said the flats were in Embankment Gardens, that two were bought using short-term bridging finance in the months before the sale, and that HMRC has until February 2027 to open an inquiry.
Setiya declined to comment. He is understood to believe the right amount of stamp duty was paid as required by law, that the properties were available for purchase from the owner collectively, and that the offer was accepted on that basis.
A spokesman for Candy said: “Nick is out of the country at present, and he will not be commenting.”
Ben Smith, a tax partner at Wilsons solicitors, said: “This case is particularly striking because of the disparity between the stamp duty payable if the house was purchased on its own, or with the five other properties.”
He added that it “undoubtedly raises questions as to the effectiveness of the ‘six or more dwellings’ rule and will prompt further calls for stamp duty reform”.
Tim Stovold, head of tax at the accountants and business advisers Moore Kingston Smith, said the rule was “intended to be used by landlords acquiring portfolios of properties without the disincentive of large amounts of stamp duty being payable”.
He added: “The situation where 99 per cent of a transaction was made up of a single property and the remaining five properties the balance of 1 per cent of value was never anticipated in the rules.”
The Conservative leader, Kemi Badenoch, pledged to abolish stamp duty at her party’s conference in October 2025.
The property has been the subject of a separate stamp duty dispute. The Times reported a double-taxation row between HMRC and Candy and his brother Christian over the stamp duty due when Providence House was bought in 2012.
Christian Candy, 52, initially exchanged contracts for £68m. He paid stamp duty of £1.92m before transferring the property to Nick in 2014, who paid the remainder of the price and a further £1.92m in stamp duty.
Christian Candy applied for a refund 18 months after the original purchase date. HMRC rejected the claim, saying it should have been made after 12 months. In July, a judge at the Upper Tribunal ruled that he should receive a refund, which came to £2.3m after interest.
Under Nick Candy’s ownership, Providence House was renovated to include a 14,000 sq ft basement with a 60ft swimming pool and a private Imax cinema.
Candy and the Australian actress and singer Holly Valance, with whom he lived at the house, announced their divorce last year, a factor the Times reported was likely to have influenced his decision to sell.
