The Upper Tribunal ruled in favour of HMRC, that property developers Christian Candy, 46, and Nicholas Candy, 48, had to each pay £1.92m on stamp duty land tax on a property they had bought in West London.

HMRC appealed to the Upper Tribunal after the First Tier Tribunal (FTT) ruled in favour of the property developers. The grounds for HMRC’s appeal was that the FTT had misunderstood the relationship between Section 44 and Schedule 10 of Finance Act 2003 which their decision was based upon.

Christopher and Nicholas Candy are the founders of Candy London, a luxury interior design and development management company. The brothers are considered to have a net worth of around £1.5bn.

The 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, which was paid in October, and then £20m.