Richard Tice‘s property company broke the law by failing to deduct £91,000 in tax from dividends paid to the Reform UK deputy leader and his offshore Jersey trust – a revelation that sits awkwardly with the party’s self-appointed reputation as the scourge of the establishment and its leader’s own statements about other politicians’ tax affairs.
Tice, who serves as Reform UK’s deputy leader and is the party’s spokesman on business, trade and energy, founded, owned and ran Quidnet REIT Ltd as chief executive. The company, which owns industrial estates in Newark and Northampton, was registered as a Real Estate Investment Trust – a special legal status that carries specific tax obligations – for almost three years between 2018 and 2021.
One of those obligations is clear in law: companies with REIT status “must, on making a relevant distribution [dividend] deduct from it a sum representing tax at the basic rate in force.” That rate is 20%. Quidnet failed to do this on at least three occasions, failing to deduct the required withholding tax before making dividend payments to shareholders including Tice himself and RJS Tice Family Settlement – his trust registered in Jersey.
What the law required and what happened
The three occasions on which the company failed to deduct the required withholding tax are set out in detail in company filings.
The first dividend, paid in March 2020, was worth £684,055 – paid not in cash but in the form of 423,040 newly created shares. Had the correct tax been deducted, Quidnet would have issued 29,300 fewer shares to Tice and his trust, and sent £47,700 directly to HMRC.
The second, paid in September 2020, was worth £289,459, issued as 186,627 new shares – effectively 5p worth of shares for every share already held. Tice and his trust should have received 4p of shares for every share held, with the difference – £20,041 – going directly to HMRC.
The third, in April 2021, was paid partially in cash and partially in shares. Tice was entitled to £55,000 in cash, from which £11,000 should have been deducted. His trust received around £64,000 of shares, from which £13,000 should have been deducted.
Across all three occasions, the total shortfall amounted to approximately £91,200. As a consequence of the underpayments, Tice received more shares than he was legally entitled to receive – meaning he continues to hold equity he would never have acquired had tax been correctly deducted at the time.
What the experts say
Dan Neidle, the founder of Tax Policy Associates and one of Britain’s most respected tax lawyers, was clear about the significance of the failure.
“The rules are fairly simple and understood by everyone in the property world,” he said. “Failure to pay the tax looks careless. We don’t get to choose who pays tax and when we pay tax, and the law required that the company paid the tax when the dividends were paid.”
On whether the matter remains live, Neidle said: “We believe it’s clear from the company’s accounts and public filings that it did not pay tax owed. The company was legally required to pay tax and, if it did not, that tax should now be paid.”
REIT companies that fail to deduct withholding tax are exposed to investigation and enforcement action by HMRC. The taxman can seek to collect unpaid taxes and issue penalties for carelessness. Crucially, the company’s legal obligations are not affected by how much tax Tice or his trust subsequently paid on the dividends. The obligation belongs to the company, not to the individual recipient.
Tice’s response
Tice implied the failure amounted to a “technicality” and suggested it did not matter because he had ultimately paid income tax on the dividends he received. He said: “I have paid all tax at the highest rate on all dividends received. HMRC has been paid in full.”
He added that he had received “professional accountancy advice,” described the revelations as “hardly a story” and said they were “just an attempt to smear a successful businessman turned politician giving hope to millions of people.”
But Neidle’s analysis directly addresses this line of defence. The question is not whether Tice personally paid tax on what he received – he says he did. The question is whether the company fulfilled its separate legal obligation to deduct the tax before making the payments. On the available evidence, it did not.
The context: Tice’s previous statements on tax
The revelations sit particularly uncomfortably in light of Tice’s own previous comments on the tax affairs of other politicians.
When Angela Rayner, the former deputy prime minister, was found to have failed to pay stamp duty on a second home purchase, Tice said her position was “morally completely indefensible” and that she would resign if she had “any moral decency.”
Last month, following an initial Sunday Times investigation into Quidnet’s tax affairs, Tice said at a press conference that he encouraged members of the public to pay as “little tax as possible.” When pressed on whether he meant that Britons should strive to pay the minimum tax legally permitted, he replied: “Yes, of course, that’s what you should do.”
That statement was made in the context of what were described as aggressive but lawful tax arrangements. Today’s disclosures go further – they concern the failure to comply with a legal obligation that Neidle says is “fairly simple and understood by everyone in the property world.”
The REIT question
The broader context of Quidnet’s REIT status itself has attracted scrutiny. Under the previous Sunday Times investigation, Neidle said it was “hard to understand” why Tice had used the REIT structure for a company of Quidnet’s size, noting that “small and medium businesses don’t normally use REITs.” He described the approach as potentially amounting to “highly aggressive tax planning.”
Quidnet qualified as a REIT for almost three years, during which it did not have to pay corporation tax – with individual shareholders instead being subject to tax on rental profits. The company avoided nearly £600,000 in corporation tax during this period by funnelling dividends to mostly tax-efficient entities. Tice withdrew from the REIT regime after 2 years and 11 months – just short of the end of a three-year grace period available to companies attempting to comply with REIT rules.
Tice owned more than 90% of Quidnet personally and through various onshore and offshore entities he controlled. He was responsible for the company’s affairs alongside two fellow directors, Nicholas Tribe, his long-term business partner, and John Purcell.
Why it matters
Reform UK has built a substantial part of its political identity on the claim that it represents ordinary people against an establishment that plays by different rules. Farage, Tice and others have been consistently vocal critics of politicians whose financial affairs fall short of expectations.
The HMRC withholding tax failure at Quidnet is not a complex or contested area of law. It is, as Neidle says, a straightforward obligation understood by everyone operating in the property sector. The law required the company to deduct the tax before paying the dividends. The company did not do so. Tice received more than he was legally entitled to receive as a result.
The question of whether HMRC will now seek to collect what is owed – and whether penalties for carelessness will be applied – remains unanswered. What is answered, at least on the available evidence, is whether the law was followed. It was not.
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