Inngrays Limited v The Commissioners for HMRC
Decision date: 23 October 2026
Neutral citation: [2026] UKFTT 1478 (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 case concerned whether an electrical substation at the rear of a five‑flat dwelling formed part of the dwelling's "garden or grounds" for SDLT purposes. The Tribunal found the substation was on a separately leased, long‑standing exclusive occupation with a self‑standing commercial function and therefore did not form part of the residential grounds. The acquisition was held to be mixed‑use and the appeal was allowed.
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 treated the question whether land forms part of the "garden or grounds" as a multifactorial evaluative exercise in which no single factor is decisive; factors such as long‑standing separate occupation, exclusive lease rights and a distinct commercial function can carry substantial weight and may support a conclusion that land is not part of the residential grounds.
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 Tribunal indicated that third‑party rights or commercial use are not automatically determinative against classification as residential grounds — the context and cumulative factors must be considered. It also suggested that the facts here resembled a quarrying‑type intrusion rather than minor intrusions (e.g. underground cables or septic tanks) when assessing whether land remains part of the grounds.