Billionaire property developer Christian Candy has won a £2 million tax battle over the purchase of a luxury Georgian mansion overlooking the River Thames.
Candy bought the Grade II listed Gordon House, which stands next to the Royal London hospital in Chelsea, in 2014, in a deal worth £68 million.
He paid the first tranche of money for the property and began extensive renovations with a 14,000 sq ft basement and the addition of a swimming pool and private Imax cinema.
In 2014, Candy handed over the property to his brother Nick Candy, who went on to complete the renovations and pay the remaining £48 million price of the leases.
Nick Candy, who is married to actress Holly Valance, still lives in the property with his family.
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As a result of the way the deal was organised, both brothers ended up paying £1.92 million in stamp duty on the mansion to HMRC.
But Christian Candy, 50, applied for a refund, and after a dispute lasting more than a decade a First Tier Tax Tribunal judge has now ruled that he should be paid the money – with interest.
The Candy brothers are among London’s most prominent luxury property developers, and they designed together the world's most expensive penthouses at One Hyde Park in 2011.
Gordon House was purchased from the Royal Hospital in August 2012, with two acres of surrounding gardens, an orangery, and a separate lodge.
Candy structured the deal so that money would be paid for two leases in instalments, with the first tranche of £7.39 million being handed over in 2013.
He gifted the property “in consideration of natural love and affection” to his brother in April 2014, and then submitted his application to HMRC for a stamp duty rebate.
He lost a 2021 Court of Appeal battle over the tax, when a judge concluded he had applied for the refund out of time – after 18 months instead of within a 12-month deadline.
But Judge Vimal Tilakapala has now allowed Candy's appeal on another basis, finding that the developer in fact had four years to seek the rebate.
HMRC said it is “disappointed” with the ruling, and may seek to appeal against Judge Tilakapala’s decision.
