Former deputy PM settles tax dispute over underpaid stamp duty on second property after HMRC decides Angela Rayner ‘acted with reasonable care’
Rayner resigned from the government last September after the furore over her failure to pay higher rate stamp duty land tax (SDLT) on a second property purchase in Hove in Sussex.
After more than eight months, HMRC has come to an agreement with Rayner, deciding that her underpayment was not ‘deliberate behaviour’ and instead she ‘acted with reasonable care’.
As a result, Rayner, who is seen as a potential leader and PM in waiting if she decides to run in Labour’s much rumoured leadership election, does not have to pay any HMRC penalty.
Instead, Rayner confirmed she has paid around £40,000 to HMRC for the underpaid SDLT. It is not clear whether interest has been charged by HMRC, which is usually the process if tax is paid late and incorrectly.
In a statement, Rayner said: ‘I welcome HMRC’s conclusion, which has cleared me of any wrongdoing.
‘I have been exonerated by HMRC of the accusation that I deliberately sought to avoid tax.
‘When purchasing a home of my own with a mortgage, I did not own any other property and had no personal financial interest in the court-instructed trust set up to manage my son’s financial award.
‘I was advised by experts that I should pay stamp duty at the standard rate.’
‘I set out to pay the correct amount of tax. I took reasonable care and acted in good faith, based on the expert advice I received, and HMRC has accepted this.
‘I have always sought to act with integrity, and I believe politicians should be held to high standards - that is why I resigned from government and cooperated fully with HMRC.’
HMRC’s investigation decided that SDLT was payable at the higher rate, 3% above standard SDLT for second home purchases.
Rayner’s office said HMRC ‘concluded that Rayner acted with reasonable care’ and she ‘had not acted with any impropriety or carelessness and that accordingly no penalty is chargeable’.
HMRC declined to comment on individuals’ tax affairs ‘due to taxpayer confidentiality law’.
The absence of a penalty has raised questions about HMRC’s decision.
Reacting to the outcome, tax expert Dan Neidle, founder of Tax Policy Associates, said: ‘That is a surprising outcome. We said last September that, on the facts as publicly stated, Ms Rayner was almost certainly “careless” within the meaning of Schedule 24 of the Finance Act 2007, and that a penalty of around 20% (about £8,000) was the likely outcome.
‘We don’t understand why HMRC reached a different conclusion.
‘We have to say at present we don’t know why HMRC accepted Ms Rayner was not “careless”. On the facts as they have been publicly stated, that conclusion seems generous.’
Further reading
Higher rates of SDLT – behind the Rayner headlines | 11 Sep 2025
Angela Rayner resigns over tax fallout | 5 Sep 2025