Christian Candy Wins Stamp Duty Refund Battle Against HMRC Over £68 Million Mansion

Billionaire property developer Christian Candy has emerged victorious in a near decade-long tax dispute against HM Revenue and Customs (HMRC), securing a £2 million stamp duty refund plus £270,000 in lost interest. This high-profile tax battle centred on the purchase of a stunning £68 million Georgian mansion overlooking the River Thames, highlighting the complexities and potential for tax disputes arising from high-value property transactions. This case serves as a significant development in the realm of property tax disputes and will be of keen interest to those involved in similar situations.

The £68 Million Gordan House Purchase and Stamp Duty Issue

In 2012, Christian Candy, aged 50, a prominent British billionaire luxury property developer, acquired the Grade II listed Gordon House in Chelsea, next to the Royal London hospital, in a deal worth £68 million. The purchase of the mansion, which boasts two acres, an orangery created by the baroque architect Sir John Vanbrugh, and a separate lodge, was made jointly with his brother Nick Candy, 52. Payments for two leases were structured in multiple instalments.

Following the initial payment and commencement of extensive renovations, including a 14,000 square feet basement, a swimming pool, and a private Imax cinema, HMRC determined that the purchase had been ‘substantially performed’. As a result, Christian Candy paid £1.92 million in stamp duty. Subsequently, in 2014, after paying £27.4 million, Christian Candy gifted the property to his brother Nick Candy, who completed the renovations and paid the final instalments. Nick Candy was also required to pay £1.92 million in stamp duty, leading to a situation of double taxation on the same property purchase. Nick Candy, who is married to Australian actress Holly Valance and is the treasurer of Reform UK, still resides in the London mansion. Christian Candy is married to socialite and former nightclub hostess Emily Crompton, whom he wed in 2010. Notably, the Candy brothers also designed the world’s most expensive penthouses at One Hyde Park in 2011.

Christian Candy v HMRC

Following the property transfer, Christian Candy sought a stamp duty refund for the £1.92 million he had paid, arguing that both brothers had effectively paid tax on the same transaction. However, in 2022, a Court of Appeal judge sided with HMRC, rejecting Christian Candy’s claim on the grounds that he had applied for the refund after the 12-month deadline following his previous tax return, having taken 18 months.

Despite this setback, Christian Candy pursued a further appeal. In a new verdict this week, delivered on 15 April 2025, Judge Vimal Tilakapala overturned the previous ruling. The judge allowed Candy’s appeal on a separate legal basis, stating that the law in fact granted him four years to lodge the claim for a tax refund. As a result of this successful appeal in the tax dispute, Christian Candy is now entitled to a £1.92 million stamp duty refund, along with approximately £270,000 in lost interest to compensate for the inconvenience caused by this protracted tax battle.

Implications of the Stamp Duty Refund Victory

This ruling marks a significant win for Christian Candy in his long-running tax dispute with HMRC. While the case was described as an unusual battle over double taxation, it highlights the importance of understanding the nuances of stamp duty rules and the deadlines for claiming tax refunds. Tax experts noted the potential cost to the taxpayer of HMRC’s decision to continue fighting the case, given the accumulating interest on the disputed amount. HMRC has stated that it is “disappointed” with the tribunal’s decision and is carefully considering the judgment, leaving open the possibility of a further appeal.

Expert London Tax Dispute Lawyers

Navigating tax disputes with HMRC can be a complex and stressful process. Our specialist team of tax dispute lawyers, including experienced solicitors and barristers, provides expert legal advice and robust representation to individuals and businesses facing challenges from HMRC. Whether you are dealing with stamp duty issues, income tax assessments, or other tax investigations, we offer tailored solutions to protect your interests. Our services include:

• Comprehensive assessment of your tax situation and potential liabilities.
• Expert advice on HMRC tax appeals and the relevant legal procedures.
• Strategic negotiation with HMRC to achieve the most favourable outcome.
• Experienced representation at the First Tier Tax Tribunal and higher courts.

If you are involved in a tax dispute with HMRC, including matters related to stamp duty, it is crucial to seek timely and expert legal advice. Contact our team today for a confidential consultation to discuss your case and understand how our expertise in tax law can assist you in achieving a successful resolution. We aim to provide clear, effective guidance and strong representation to help you navigate the complexities of tax disputes and reach a positive outcome.