Conservatives demand HMRC investigate Rayner’s possible tax fraud

Today [Thursday 4^th September 2025] the Conservatives are demanding that His Majesty's Revenue and Customs urgently investigate Angela Rayner's possible tax evasion.  

After weeks of pressure from the Conservatives, Angela Rayner has finally admitted that she underpaid Stamp Duty by £40,000 when purchasing her property in Hove. 

This admission new leaves fresh questions about Rayner's tax affairs – and whether she knowingly and willingly underpaid Stamp Duty.  

That is why Kevin Hollinrake, Conservative Party Chairman, has now written to HMRC demanding that they investigate the Deputy Prime Minister.  

In his letter to Penny Ciniewicz, Director General and copied to Sir Laurie Magnus, Independent Adviser on Ministerial Standards, Kevin raises the glaring inconsistency of declaring to the Cabinet Office and Tameside Council that Ashton-under-Lyne is her primary residence, whilst declaring to HMRC that Hove was her primary residence – allowing her to avoid the Stamp Duty surcharge.  

Kevin also raises whether “the tax evasion was deliberate, to try to get away with minimising her upfront costs” as well as the fact that the “claim of reliance on defective advice is therefore not a defence, but further evidence of opportunistic inconsistency. It demonstrates that she deployed contradictory positions deliberately to reduce her personal liabilities.”

Kevin requests that HMRC not only fully investigates the matter but also considers the application of a penalty for tax evasion. Such a penalty could be between £12,000 - £40,000, per HMRC guidance. 

The full text of Kevin Hollinrake's letter is below: 

“Dear Ms Ciniewicz

INVESTIGATION INTO TAX EVASION BY THE DEPUTY PRIME MINISTER

I am writing to you further to your responsibilities within HMRC as the lead for ‘tackling those who cheat the system'.^[1]

As you will be aware, the Deputy Prime Minister, Angela Rayner, has made a public statement that in May 2025, she purchased a home in Hove and “I did not pay the appropriate stamp duty at the time of the purchase”. Based on the £800,000 value of the house, and higher rates of stamp duty introduced under the Labour Government, this means she did not pay the £40,000 second homes surcharge to HMRC.

The Deputy Prime Minister has maintained that Ashton-under-Lyne is, and has remained, her primary home. She is not paying council tax on her Ministerial residence in Admiralty House in London on the basis that Ashton-under-Lyne is her primary residence. Someone can only have one primary residence (often in law referred to as one's “sole or main residence”).

In that context, I would question why the Deputy Prime Minister felt she did not regard the Hove residence as a secondary residence (technically, her third). Why did she, or her representatives, not take the necessary steps to check with HMRC on whether second homes stamp duty was actually payable.^[2] This was “careless” at best, and did not meet her requirement to act responsibly.

She was aware that she retained a financial interest in her Ashton-under-Lyne house for the trust, and had not completely removed herself from the Land Registry. On that basis, there is a reasonable prospect that she could have been liable for second homes stamp duty.

In her public statement she acknowledged: “my understanding, on advice from lawyers, was that my circumstances meant I was liable for the standard rate of stamp duty … I acknowledge that due to my reliance on advice from lawyers which did not properly take account of these provisions, I did not pay the appropriate stamp duty at the time of the purchase.”

This contention of innocent reliance on defective advice cannot withstand scrutiny. To the Cabinet Office and Tameside Council, she has declared Ashton-under-Lyne as her primary residence. That classification enabled Admiralty House to be treated as a second home, with the result that her London council tax liability was transferred to the taxpayer. To HMRC, however, she acted as though Ashton-under-Lyne was not her primary residence, having removed herself from the substantive title (albeit not fully) in order to avoid the £40,000 higher-rate stamp duty surcharge on her Hove purchase.

If her legal advisers had truly failed to identify the relevant deeming provisions in the stamp duty regime, her reliance upon that advice would have been uniform. Consistent reliance would have led her to maintain throughout that Ashton-under-Lyne remained her main residence. The fact that she advanced opposite positions to different authorities demonstrates that she was not passively relying on one piece of defective advice, but rather tailoring her representations to secure advantage in each forum.

There are legitimate questions on whether Ms Rayner could have afforded the property if she had been liable for the additional £40,000 in second homes stamp duty, on top of the £30,0000 standard stamp duty and the £150,000 downpayment towards the Hove flat. This then raises the question whether the tax evasion was deliberate, to try to get away with minimising her upfront costs so she could afford her £650,000 Natwest mortgage (which is likely to cost in the region £4,000 a month to service).

I am requesting that HMRC undertake a full investigation into this matter and consider the application of a penalty for tax evasion. I note that HMRC guidance on this issue recommends a penalty based on Potential Lost Revenue, of 30 per cent of the revenue for an “careless” inaccuracy (which would be £12,000), to 100 per cent (£40,000) for a deliberate inaccuracy.^[3]

You may wish to obtain a copy of the ‘advice' that she claims to have had, inspect her multiple title deeds on the Land Registry, and obtain a copy of the declaration of trust from 2023. Was this ‘advice' actually from a tax lawyer or chartered tax adviser? I note that the Deputy Prime Minister has previously tried to hide behind undisclosed tax advice over the controversy on capital gains tax and her Right to Buy house.

More broadly, this raises wider questions on whether she has made other false statements allowing her to avoid the personal payment of council tax.  How can she credibly maintain to Cabinet Office and Tameside Council that Ashton-under-Lyne is her primary home, given she sold her substantive stake in the home (other than her trust interest)? How many days a week does she actually reside in her homes in (a) Ashton-under-Lyne, (b) Westminster and (c) Hove?

By acting in this way, the Deputy Prime Minister obtained material benefit in both directions: the avoidance of the £40,000 surcharge from HMRC, and the shifting of her London council tax liability to the public purse. The claim of reliance on defective advice is therefore not a defence, but further evidence of opportunistic inconsistency. It demonstrates that she deployed contradictory positions deliberately to reduce her personal liabilities.

Such conduct falls foul of paragraph 3.11 of the Ministerial Code, which requires that a minister allocated an official residence must “ensure that all personal tax liabilities, including any council tax, are properly discharged and that they personally pay such liabilities”. It is also inconsistent with the principles of integrity and honesty set out in the Nolan Principles on standards in public life, which require that ministers must not act to secure material benefit for themselves and must be truthful.

I am placing this letter in the public domain and copying it to the Independent Adviser on Ministerial Standards.

Yours sincerely,

Kevin Hollinrake MP, Chairman of the Conservative & Unionist Party”

ENDS 

Notes to Editors 

^[1] https://www.gov.uk/government/people/penny-ciniewicz 

^[2] https://www.gov.uk/find-hmrc-contacts/stamp-duty-land-tax-general-enquiries 

^[3] https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm85905 and 

https://www.gov.uk/hmrc-internal-manuals/compliance-handbook/ch82120