In this case at the First Tier Tribunal, the appellants Jessica Harjono and Yusdi Santoso, disputed a charge for additional stamp duty land tax (SDLT) for the purchase of a property with a paddock subject to a grazing agreement.

The buyers claimed that the paddock should be defined as mixed use as it was subject to a grazing agreement in favour of a third party, Zoe Donnelly. They also stated that the paddock should not be considered as part of the ‘grounds’ of the dwelling (a barn conversion) at the relevant time.

On 20 December 2021 the appellants’ purchased the £2.7m Culverton Barn, a five reception room, six bedroom barn conversion in a village near Oxford with three acres of land.