&, Conservatives James Daly MP Deputy Chairman of the Conservative and Unionist Party 4 Matthew Parker Street London SW1H 9HQ Monday 25 March 2024 Dear Mr Cullen, Tam writing to you regarding a former employee of Stockport council. As you will be aware, there has been significant media and public concer over Angeb Rayner's living arrangements between 2007 and 2015. It is my understanding that Greater Manchester Police are currently re-assessing whether to investigate the information she provided on the electoral register during this time. There is a strong public interest in this matter, given it relates to a figure who holds public office (a Member of Parliament); who wishes to obtain high public office (as a Cabinet Minister and Deputy Prime Minister); who seeks to be the Secretary of State responsible for both electoral law and local government; and who has made public comments criticising others on tax avoidance. Talso understand that in this period, Ms Rayner was also an employee of the local authority (under trade union facility time). Itis of the highest importance that employees of the coundl uphold the law in relation to the council itself. The council will hold information that the police do not currently have, which could be a material consideration on whether a more formal investigation should be initiated by the police and/or the council itself. Criminal or civil penalties may apply. There are two issues which directly relate to the statutory duties and responsibilities of your local authority. Firstly, under Section 13D of the Representation of the People Act 1983 (as amended), there is a criminal offence in relation to the provision of false information ("A person who for any purpose connected with the registration of electors provides to a registration officer any false information is guilty of an offence”). This interacts with Sections 4 and 5 of the Act, which provide the basis for entitlement to be registered on the electoral reaister. If an individual has a permanent residence elsewhere, then generally, they should register at that address. This is particularly pertinent in relation to having two notional addresses in the same local authority area (as opposed to a temporary residence elsewhere — e.g. student halls during term time, may have two addresses). Regarding 80 Vicarage Road, Ms Rayner has stated that “[she] stayed there, [her] brother stayed there, he stayed at different various points.” Conservative Campaign Headquarters | 4 Matthew Parker Street, London, SW1H SHQ | 20 7222 9000 | conservatives.com@% Conservatives If Ms Rayner’s actual permanent address was 126 Lowndes Lane, where her children and recently married husband resided, then she should not have been registered, and re- registered over that continued period, at Vicarage Road. Similariy, if her brother was permanently residing at Vicarage Road, and not at Lowndes Lane, then he should have been registered at Vicarage Road and not at Lowndes Lane. It would be a false statement for Ms Rayner to deciare otherwise on the household registration form or any individual registration form. Do you til hold the electoral registration form for the Vicarage Road address from this period? This could provide evidence of such a false statement for any police investigation into her registration on the electoral register if she signed it. Secondly, during this period, did Ms Rayner claim a single-person discount on council tax for the property at Vicarage Road? Under Section 6, Section 11 and Schedule 1 of the Local Government Finance Act 1992 (as amended), the single-person discount can only be claimed for one’s “sole or main residence”. It cannot be claimed on a second home. There can only be one adult resident in the dwelling (unless otherwise the adult is disregarded - e.g. full-time students). If Ms Rayner was mainly or solely living at the property on Lowndes Lane, she could not lawfully claim a single-person discount on the address at Vicarage Road. I note the guidance given by the Valuation Tribunal Service's Council Tax Manual, which cites the case law of Cox v London South West Valuation Tribunal HC (RVR 1994 171). They observe: “the taxpayer spent time at two dwellings. The High Court concluded that the sole or main residence was the home where the wife and family resided.” If her brother was actually living in the house on Vicarage Road, and she mainly resided in the same property (as her electoral register would notionally suggest), they could not lawfully claim a single-person discount. They would have joint and several liability to pay the full rate of council tax. However, if her brother was living in the house on Vicarage Road, but she was not, whilst this, would not be a breach of council tax law, it would confirm that electoral law had been broken. Section 2 and Section 3 of the Fraud Act 2006 provides for local taxation fraud offences, by false representation or by failing to disclose information, Civil penalties can also be applied under Schedule 3 of the Local Government Finance Act 1992 fora person who negligently supplies incorrect information which affects their liability or entitlement to a council tax discount; this is in addition to the recovery of the associated council tax discount. Civil penalties would be a matter for the council and/or Valuation Tribunal Service. Criminal penalties would be a matter for the police, but the evidence held by the council would be material. Conservative Campaign Headquarters |4 Matthew Parker Street, London, SW1H 9HQ | 020 7222 9000 | conservatives.com@% Conservatives T look forward to hearing from you. Au? James Daly MP Deputy Chairman of the Conservative and Unionist Party Yours sincerely, Conservative Campaign Headquarters |4 Matthew Parker Street, London, SWIH 9HQ | 020 7222 9000 | conservatives.com