The Executor of The Estate of Paul Goudman-Peachey v The Commissioners for HMRC
Decision date: 24 November 2025
Neutral citation: [2025] UKFTT 1402 (TC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
This appeal concerned whether the January 2019 purchase of Woodmancote Place and c.150 acres was entirely residential for SDLT or mixed‑use. The Tribunal found the main house and immediate gardens were residential but substantial adjacent land was in separate non‑residential use (deer park, sheep grazing, arable use, and a long‑term ROWL easement), so the transaction was mixed‑use. HMRC’s closure notice treating the whole acquisition as residential was overturned and non‑residential/mixed‑use (Table B) SDLT rates apply.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: high
The Tribunal’s ratio is that, for s.116 FA 2003, whether land adjoining a dwelling forms its "garden or grounds" is an evaluative question at the completion date: where adjoining land has a self‑standing commercial or agricultural use (considering historic and factual use, layout, proximity, extent and legal constraints) it will not be treated as the dwelling’s grounds and the transaction can be mixed‑use.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The judgment recorded that third‑party rights (public footpaths, easements) do not automatically exclude land from being grounds but are relevant factors in the evaluative exercise, and that arrangements entered into after the effective date are generally irrelevant to characterisation; these propositions were treated as guidance rather than dispositive holdings.