Deputy Prime Minister Angela Rayner MP resigned

5th September 2025

Letter from the Independent Adviser to the Prime Minister.

Independent Adviser on Ministerial Standards
Sir Laurie Magnus CBE
5 September 2025.

Dear Prime Minister,
Following a self-referral by The Rt Hon Angela Rayner MP, Deputy Prime Minister and
Secretary of State for Housing, Communities and Local Government on 3 September 2025, I
have undertaken an examination of the circumstances and facts connected to recent
allegations about Ms Rayner’s property ownership and tax affairs.
I should acknowledge that Ms Rayner has provided her full and open cooperation in assisting
me with my inquiries. Her decision to provide greater public transparency by applying to
remove the confidentiality undertaking in a court order protecting her family's domestic
financial circumstances was, in particular, clearly very difficult to reconcile with her
understandable wish to shield members of her family from the glare of media attention. It is a
sad reflection of the almost intolerable pressures that can face prominent politicians in
protecting the privacy of their families, not least, as Ms Rayner highlighted in her statement
on 3 September, "the reality that family life is rarely straightforward, particularly when
dealing with disability, divorce and the complexities of ensuring your children's long term
security".
Ms Rayner has explained publicly that, following recent allegations and speculation, and in
order to assure herself of compliance with her obligations, she sought legal advice from
leading tax Counsel. This covered her personal position in relation to council tax, stamp duty
land tax, capital gains tax and inheritance tax. I have had access to this written opinion and,
as a result of its conclusions, have focused my inquiries - and this advice - on the issues
relating to Ms Rayner's acknowledged failure to pay the correct amount of stamp duty land
tax (SDLT) on the purchase of a property in Hove, Sussex, in May 2025. It is the realisation
of this error that prompted Ms Rayner, shortly after having received the final tax law advice,
to refer the matter to me on Wednesday 3 September.
Ms Rayner has set out in detail, publicly, the details of her family's domestic arrangements
and her decision to sell her 25% interest in the freehold of the family home in
Ashton-under-Lyne and to purchase a property in Hove. I do not need to repeat these details
here, other than to note that they inevitably entailed a considerable degree of complexity.

Having sold her 25% share in the family home in
Ashton-under-Lyne, Ms Rayner ceased to
own any part of that property. However, under the relevant legislation, a person who does not
own a property can nonetheless be deemed to hold an interest in it if certain circumstances
apply; these include where that property is held by a trust, and the beneficiary of the trust is a
child of that person under the age of 18. I understand there are additional complexities, for
example concerning the particular type of trust in question and the reason for which the trust
was established. Taken together, it appears that - particularly in the context of the specialist
type of trust in question - the interpretation of these rules is complex.
With Ms Rayner’s full cooperation and assistance, I have reviewed relevant documentation
from the property transaction. This has included the advice she received at the time from the
legal firms involved and the associated documentation that was prepared for her to effect the
purchase. This advice gave rise to Ms Rayner's understanding - which I consider to have been
held in good faith - that the lower rate of SDLT was applicable when purchasing the property
in Hove.
It is not necessary for me to detail the specific contents of this advice or the associated
documentation but, having reviewed it, I would draw four conclusions:
a) Ms Rayner was open about the existence of the Trust and considered that, between
them, the firms advising her had appropriate knowledge and awareness of the details
and circumstances of the Trust;

b) on the basis of the advice she received, Ms Rayner believed that the lower rate of
SDLT would be applicable; indeed she was twice informed in writing that this was the
case; but
c) in those two instances, that advice was qualified by the acknowledgement that it did
not constitute expert tax advice and was accompanied by a suggestion, or in one case
a recommendation, that specific tax advice be obtained; and
d) if such expert tax advice had been received, as it later was, it would likely have
advised her that a higher rate of SDLT was payable.
The Ministerial Code sets out the high standards that, as Prime Minister, you expect all
ministers to follow. It enshrines the commitment to uphold the Seven Principles of Public
Life, and details "the overarching duty on Ministers to comply with the law and to protect the
integrity of public life". The Code begins at 1.2 by stating that “Ministers are expected to
embody the principles of public service and to set a positive example as they govern in the
national interest. Ministers should recognise that, as office-holders, they are held to the
highest possible standards of proper conduct, and ensure that they are living up to those
standards in their words and actions".

Ms Rayner deeply regrets the mistake she has made in relation to the underpayment of SDLT
for the purchase of her property in Hove. On realisation of this error, she has sought quickly
to correct the mistake and to refer herself to HMRC in order to ensure that she pays the
correct amount. I have no doubt that she has been motivated in the management of her
property and financial arrangements by a desire to act in the best interests of her children, and
with the intention to pay all appropriate taxes and fulfil all her legal obligations.
It is highly unfortunate, however, that Ms Rayner failed to pay the correct rate of SDLT on
this purchase, particularly given her status and responsibilities as the Secretary of State for
Housing, Communities and Local Government and as Deputy Prime Minister. She believed
that she relied on the legal advice she had received, but unfortunately did not heed the caution
contained within it, which acknowledged that it did not constitute expert tax advice and
which suggested that expert advice be sought. I am conscious of the acute challenges
Ministers face - perhaps uniquely - in managing the demands of their personal lives and their
public responsibilities. However, the responsibility of any taxpayer for reporting their tax
returns and settling their liabilities rests ultimately on themselves alone. Given the
conjunction of the acknowledged complexity of her family circumstances, her position in
Government (most importantly as Deputy Prime Minister) and the consequences of getting
such a calculation wrong, it is deeply regrettable that the specific tax advice was not sought.

I believe Ms Rayner has acted with integrity and with a dedicated and exemplary
commitment to public service. I consider, however, that her unfortunate failure to settle her
SDLT liability at the correct level, coupled with the fact that this was established only
following intensive public scrutiny, leads me to advise you that, in relation to this matter, she
cannot be considered to have met the “highest possible standards of proper conduct” as
envisaged by the Code. Accordingly, it is with deep regret that I must advise you that in these
circumstances, I consider the Code to have been breached.

Yours sincerely,

Sir Laurie Magnus CBE
Independent Adviser on Ministerial Standards