Stamp Duty questions raised about Britain’s largest property purchase
Tax expert Dan Neidle has done the sums on Britain's largest property purchase and examines the amount of Stamp Duty paid.
A tax expert has questioned how much Stamp Duty was paid for Britain’s highest property purchase earlier this year.
Well-known property developer Nick Candy sold Providence House in Chelsea in May for a reported £265million to hedge fund manager Suneil Setiya.
It is the most expensive house ever sold in Britain.
But analysis by London Centric and Tax Policy Associates, suggests the way the house was sold legally avoided around £18.5million of Stamp Duty.
We think it will be of public interest that the most expensive house in British history was acquired using such a structure.”
Dan Neidle, founder of Tax Policy Associates, says ordinarily a £265million house purchase would come with a £32million Stamp Duty bill.
But due to a loophole in the rules, only around £13million of Stamp Duty was paid on the purchase, according to the research.
Tax Policy Associates highlights that the property was sold through Providence House LLP, which was incorporated on 11th October 2024 by Candy, his wife Holly Valance and a second LLP whose own members are two long-standing Candy advisers.
The sale to Setiya in May 2026 included five other flats that Candy had previously transferred into the LLP.
It is this structure that meant it could use the Stamp Duty rules to apply for a lower rate of 5% instead of 12% as a commercial rather than residential transaction.
Six property structure
This is based on the Finance Act 2003 which says: “Where six or more separate dwellings are the subject of a single transaction involving the transfer of a major interest in, or the grant of a lease over, them, then, for the purposes of this part as it applies in relation to that transaction, those dwellings are treated as not being residential property.”
Neidle says: “We think it will be of public interest that the most expensive house in British history was acquired using such a structure. And there’s an important question: did the structure work? Or will HMRC be able to recover the £18.5million?
“If not, then past experience suggests this scheme may start to be used by others buying high-value properties unless and until HMRC close it down.”
It is understood that the parties believe the right amount of Stamp Duty was paid.
Setiya declined to comment. Candy has been asked for comment.
