Christian Candy has won his £1.92m SDLT case at the FTT appealing against a closure notice issued in August 2015. Previous appeals from the billionaire property developer at the Upper Tribunal and the Court of Appeal upheld HMRC’s decision as the SDLT repayment claim had been made out of the 12-month amendment window.

The Court of Appeal hearing that Candy lost took place in 2021.

The original case arose after Christian Candy agreed to purchase Gordon House from the Royal Hospital Chelsea in 2012 where he exchanged contracts, consisting of two lease agreements for £48m, and then £20m.

Christian Candy began substantial building work worth £27m before finishing the purchase, including a 60ft swimming pool and a cinema. The works triggered the ‘substantially performed’ clause under section 44 of the Financial Act 2003 which meant that Christian Candy had to pay the stamp duty tax levy of £1.92m.

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