HMRC Clears Angela Rayner of Wrongdoing After She Paid £40,000 in Additional Stamp Duty on Hove Flat

HMRC has cleared Angela Rayner of any wrongdoing over her tax affairs, concluding there was no tax avoidance and imposing no penalty after she paid an additional £40,000 in stamp duty on her £800,000 flat in Hove. The authority determined she was not careless in her approach to the transaction. She had initially paid £30,000 in stamp duty when she bought the property.

The higher rate applied because she had sold her 25% share in the family home in Ashton-under-Lyne to her son's trust in January 2025. The trust had been set up in 2020 using a payment granted after a medical incident when her son was a premature baby. Her son has lifelong disabilities including blindness and is now in his late teens.

Rayner has two sons with her ex-husband Mark Rayner and one from an earlier relationship when she was 16. She divorced Mark Rayner in 2023. The couple agreed to a nesting arrangement after their divorce in which their son remains in the family home full-time while they alternate living there. Some of the interest in the Ashton-under-Lyne family home was transferred to the son's trust in 2023.

She used a £162,500 lump sum from selling her stake in the constituency home in Greater Manchester for the deposit on the Hove flat. Rayner stood down as deputy prime minister in September 2025 after admitting underpaying stamp duty. She referred herself to the ministerial ethics adviser after admitting she had wrongly listed her flat.

She was later advised that complex provisions relating to the trust give rise to additional stamp duty liabilities despite not owning any other property at the time of purchase. Ministerial ethics adviser Sir Laurie Magnus issued a report stating Rayner breached the ethical code.

Sir Laurie Magnus stated that Angela Rayner’s understanding of the tax she owed was held in good faith but she did not seek specific tax advice.

The authority did not impose a penalty on her. Rayner commissioned the opinion of KC Graham Aaronson who argued HMRC was relying on too strict an interpretation of the law. Graham Aaronson pointed to paragraph 12 of Schedule 4ZA of the Finance Act 2003 regarding an exemption for trusts for disabled children.

Shadow chancellor Mel Stride introduced the trust exemption to the Finance Act when he was a Treasury minister.

In a statement, Angela Rayner said she welcomes HMRC’s conclusion which has cleared her of any wrongdoing. “I have been exonerated by HMRC of the accusation that I deliberately sought to avoid tax,” she stated. ” She added: “I set out to pay the correct amount of tax.