The snake-oil salesman of Reform – is he fit to run our Exchequer?
henry tapper
From a spiv stealing from the Exchequer?
In case you’re confused – the £100k of tax @TiceRichard failed to pay here is totally different to the
– £92k of tax not properly withheld on dividends
– the £600k side-stepped via highly aggressive tax avoidance
Industrial scale grifting revealed by @Gabriel_Pogrundhttps://t.co/EekZnYapAE
He has dismissed all scrutiny of his affairs, describing a previous investigation by this newspaper into his “aggressive”, but apparently legal, tax avoidance as an attack on a “successful businessman”. He dismissed subsequent evidence he failed to pay tens of thousands in tax as a “technicality”.
On Saturday night, after declining to respond to our inquiries, Tice published a statement addressing his wider tax affairs. He said: “Naturally I am always happy to put things right and if numbers need rechecking, of course I will pay what is owed — be that more or less”. He accused The Sunday Times of unspecified “assumptions, numbers and dates” that were “incorrect”. He said he would no longer be “indulging” the newspaper and claimed our reporting constituted part of a “smear campaign”. He did not dispute or challenge any specific part of our reporting.
The latest developments also pose questions for Farage, who turned to Tice to run and bankroll Reform between the 2019 and 2024 elections when he considered retiring. During the period in question, Tice served as either leader or chairman.
Farage defended Tice last week and was accused of “snapping” at a reporter who asked him to provide evidence for his deputy’s claim that HMRC was not left out of pocket. The Reform leader would not do so and referred to the complexity of tax rules.
The latest disclosures relate to four companies run by Tice and registered an address in Berkeley Square, Mayfair, all of which are required to file publicly available accounts. Tisun 1, Tisun 2 and Tisun 3, were formed on the same day in July 2018. Tisun 4 was created two years later. In official filings, all describe the “nature” of their business as that of a “dormant company”. Records suggest their sole role was to receive payments from Quidnet in which they held shares. Quidnet rents out eight nondescript industrial estates it owns from Newark and Northampton to Wigan. Its biggest premises is a 159,000 sq ft site in Darlington, once used by British Steel.
This is all about corporate tax but Torsten Bell has picked up on the personal aspect of this
The accounts state that Tice wrote off the whole “expected” tax bill of each Tisun entity, leading to a bill of zero. According to the analysis of several professionals we consulted, he should have instead taxed the payments, totalling £517,694, at the normal rate of corporation tax, then 19 per cent, leading to a bill of £98,362.
Tice offered two different explanations for why he did not pay tax on the profits when first asked by this newspaper some weeks ago.
One was that Tisun Investments, the parent group of Tisuns 1-4, made overall losses, meaning by law the subsidiaries did not need to pay tax. Tice said over WhatsApp: “[Tisun] had losses overall … so tax is paid/offset in the group.” He added that “the accountants will have applied the group taxation rules fully” and that any due tax would have been paid at “the group level”.
Neidle was one of several specialists who examined this argument. He, like the others, concluded it was not a viable theory: the parent group had not suffered the kind or scale of losses required for Tice to have written off the tax bill of each entity each year. In addition, there was no reference to parent losses in any of the relevant accounts, which, according to Neidle, there ordinarily would be if this applied.
This is the industrial scale grifting referred to by the pension minister Torsten Bell
The other reason Tice put forward is that “companies don’t usually pay tax on divis [dividends] from other UK companies”. While this argument is not legally correct in the circumstances — these were taxable PIDs, not tax-free normal dividends — it does tally with the story presented in the accounts. These explicitly state that he paid no tax by attributing 100 per cent of profits to non-taxable “dividend income”. But they go further still.
The accounts can also be downloaded in a machine-readable format called iXBRL. This includes information invisible to the human eye, but “visible” to computers, for each piece of text. In this scenario, we can specifically see that Tice, or someone working for him, used accounting software to generate his accounts and reduced his tax bill by inserting his profits into a box marked “dividend income”. This generated an invisible tag referring to the “effect [of] dividends”.
Tice with Farage and other Reform members at the party conference in September
It is a criminal offence for a director to “recklessly” provide false information on company accounts. Tice as sole director was responsible for submitting returns and filing accounts.
Over the years in which tax was not paid — 2020 to 2022 — Tisuns 1-4 passed their profits to Tisun Investments Ltd, which, via a holding company, Tisun Holdco Ltd, is owned by Tice. According to the Electoral Commission, during the same period, Tisun Investments loaned £1.113 million to Reform in 36 payments. Several of the loans (worth a combined £350,000) were converted into gifts years later.
Neidle said there was no ambiguity about the rate at which the payments to Tisuns 1-4 should have been taxed. He said: “This is a basic rule, not a grey area, and one widely understood across the industry.” He pointed to the fact that Tice himself had made the unusual decision to convert Quidnet into a real-estate investment company, a tax-efficient legal status whose key feature is that profits are paid out as PIDs, not ordinary dividends. Quidnet even referred to “PIDs” in the company’s accounts and stock market announcements.
If this is what Tice calls “being good at making money” then I hope we hold him in the same regard as we do one American politician.
Neidle said: “The fact the difference was missed repeatedly, across multiple companies and years, raises obvious questions.”
Tice, his lawyer and Reform did not respond to our inquiries. Several weeks ago Tice told us that “no questions have been asked by HMRC so I trust them more than whoever is advising you”.
The story of Tice’s complex tax affairs begins in September 2018. He was becoming increasingly involved in eurosceptic politics and would be appointed as chairman of the Brexit Party, the forerunner to Reform, founded by his friend Farage, within weeks.
Still, he had no intention of leaving the property world he had worked in since his twenties — and which had made him his first millions. He had particularly big ambitions for the company he had created a few years earlier.
On the face of it, Quidnet was an unglamorous collection of industrial estates and business parks in Newark, Northampton and West Sussex. Its properties were worth £12 million, small fry compared with the investments he had managed firstly as chief executive of his grandfather’s property group, which he ran from the age of 27, and later as chief executive of CLS Holdings Plc, a FTSE-250 listed company.
But Tice wanted to take Quidnet’s activity to the next level. That September, having already taken the required first step of listing it on the Guernsey stock exchange, he applied for it to become a real-estate investment trust (REIT). REITs tend to manage billions of pounds of property — British Land Plc is one well-known example — and are designed to widen access to commercial property for retail investors. The company pays out profits on a regular basis, with shareholders, not the company itself, left to pay any resulting tax. As Tice himself reported in that year’s accounts, the structure is “attractive for those seeking high income in a tax efficient manner”.
The status was not, however, designed for companies like his. His was not just a modestly sized firm, but, critically, one more or less wholly owned by him via a collection of mostly tax-efficient entities: an offshore trust, a pension investment trust, the newly created shell companies Tisuns 1, 2 and 3, and latterly Tisun 4. In fact, the rules actually exclude companies like his from acquiring the status — they have to be owned by lots of people, or be “open”, not “close”, as the law defines it.
Yet Tice was able to benefit from a loophole. Quidnet had a three-year grace period — starting then, in September 2018, and ending in September 2021 — in which it could find new investors in order to meet the conditions for permanent existence as a REIT.
Tice did not use the time as intended. He never secured anything like the number of outside investors required. In fact there is no evidence he shared investor materials publicly and when we asked for a copy of such information, he declined, citing “confidentiality”. While Tice brought on board some colleagues as small shareholders, and an investor operating via the Channel Islands, he always owned more than 90 per cent of the company and so was forced to forfeit the status after two years and 11 months.
Yet in the meantime, his company enjoyed all the tax-perks of REIT status, and did not have to pay a penny in corporate tax on its profits. That amounted to a saving of £600,000. Tice’s shareholder structure made him further savings. One requirement of REITs — even those in the “grace period” — is that they regularly shell out profits in payments to shareholders. Tice was, for all intents and purposes, the owner of the company but he did not own all of its shares personally. If he had, he would have paid income tax on any payments, but, instead, several of the entities that owned slices of the pie on his behalf were not required to pay any tax at all due to their status.
When The Sunday Times first revealed his unusual company structure last month, Neidle, the tax expert, said the arrangement looked “aggressive”.
Tice said there was no problem. He avoided tax, did not evade it, and had done nothing wrong, he claimed. To such criticism, Tice had a simple narrative. He said the story was a “smear”. He said Neidle, whose investigations have covered Keir Starmer and Angela Rayner as well as Nadhim Zahawi, was biased in favour of Labour. He opened a Reform conference in Westminster on March 16 by selectively quoting from The Sunday Times’s output the previous day and, when asked if Britons should avoid as much tax as legally possible, said “yes”.
The tenor of the conversation changed last Sunday, however, when this newspaper further reported that, for all the legitimate, and apparently legal, tax perks of its status, Quidnet had actually broken the law. One thing REITs are required to do is deduct a certain amount of tax before making payments to certain kinds of shareholders. But Tice did not do this. HMRC was left at least £91,000 out of pocket as some investors received payments that were far too large. This time, Tice described it as a “tax technicality” and offered a political, rather than legal argument: he claimed that by overpaying himself, he had ended up paying more income tax, meaning the taxman eventually received the same sum anyway. When asked to give evidence of this, he refused. In addition, there is no legal way for a company to write off its tax bill simply because another party has paid more tax as a result of the company’s previous non-payment.
The day after that story was published, Farage was asked about the failure and responded abruptly, telling a reporter to give him a “lecture” on the nature of REITs.
Today’s disclosures reveal Tice repeatedly signed off accounts describing the payments made to Tisuns 1-4 as something specialists say they were not — ordinary dividends — when they could only have been PIDs, meaning tax should have been paid. Over several years, the accounts, which were personally signed off by the Reform deputy leader, include a line for the “expected” tax bill — the amount the company should have paid — followed by a section headed “dividend income”, which shows the profits for the previous year being deducted from the bill. By the following line, the “actual” tax bill is zero. Last week Tice refused to respond to analysis indicating that, in fact, every penny should have been taxed at the normal rate of corporation tax.
To a layperson, accounts are difficult to comprehend and often include complex accounting jargon. But, thanks to a feature of modern accounting, we are able to confirm that Tice did indeed state that the tax could be written off as tax-free dividends. Since 2011, all UK companies have been required to submit accounts to Companies House, the UK’s official government registrar of companies, in a format known as iXBRL, which means they can be read by a computer as well as humans. Such data is published and is available to the public.
The iXBRL files for the Tisun companies show that Tice, as director, completed his accounts using CCH, a piece of software run by Wolters Kluwer, a Dutch firm. It also lets us see exactly what steps Tice, or his accountant, took when using the software to generate certain sections. In particular, we can see that the Tisun entities filled in the tax section by reporting the amount of money received in property income distributions (PIDs) as dividends instead — and inserted the total payments received into a section called “dividend income”.
This human act led to the generation of an invisible tag — Tax Increase Decrease From Effect Dividends From Companies — which means the tax bill has fallen because of the effect of dividends being taken into account. Adam Mohamed, of the Financial Reporting Council, confirms the code generated represents “the adjustment to the total tax charge caused by dividends received from companies being taxed at a different rate than the [normal] rate”.
During the period in question, Tisuns 1-4 transferred their profits to their parent group, Tisun Investments Ltd. During the Brexit Party’s transition to Reform UK, the limited company was one of Farage’s largest funders, making several dozen loans worth more than £1 million and later converting them to the gifts.
Without the money, Reform would have been deprived of one of its biggest sources of income at a time when it was recovering from the 2019 general election, in which it ultimately agreed to stand down most candidates and was preparing to become a major force by the time of the next election.
For that, Farage has Tice to thank — and Tice, it seems, has even more questions to address.
