Questions have been raised by tax experts regarding the stamp duty payment for the £265 million sale of Providence House, a residential property in Chelsea that holds the record for Britain’s most expensive transaction. The seller, property developer Nick Candy, transferred ownership to hedge fund manager Suneil Setiya in May. An analysis conducted by London Centric and Tax Policy Associates indicates that the transaction’s structure may have resulted in a reduced stamp duty liability of around £18.5 million.
A typical purchase of a £265 million house would usually incur a £32 million stamp duty fee, according to Dan Neidle, founder of Tax Policy Associates. However, the research suggests that the actual amount paid was approximately £13 million. The property was sold through Providence House LLP, a company incorporated on 11 October 2024 by Candy, his wife Holly Valance, and another LLP with two long-standing Candy advisers as members. As part of the sale, five additional flats previously transferred into the LLP by Candy were also included.
Commercial classification
The use of this structure allowed the transaction to be categorized as commercial, rather than residential, resulting in the application of a 5% rate instead of the 12% residential rate. This approach is rooted in the Finance Act 2003, which considers six or more separate dwellings involved in a single transaction as non-residential property for stamp duty purposes. Neidle commented: “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 £18.5 million?”
