This case concerned stamp duty land tax (SDLT) and whether fields acquired with a residential property formed part of the “grounds” of the property under section 116 of the Finance Act 2003. The Tribunal held that the fields were functionally occupied with and were appendages to the property and did not have a self-standing function at the effective date of the transaction. The fact that the land was capable of agricultural use, had historically been used for agricultural purposes, or was crossed by public footpaths did not prevent it from being treated as residential property. The Tribunal also held that the fields did not need to be necessary for the reasonable enjoyment of the dwelling or directly accessible from it in order to constitute its grounds. Accordingly, the entire property was residential property for SDLT purposes and the appeal was dismissed. For more information, please view the judgment below: