מדרש על ביכורים 1:1

If "from your land," I might think (that he may bring bikkurim) even if he plants in his (field) and engrafts into (another) individual's (field); or if (he plants) in a public field and engrafts from a public field; or from an individual's (field) into his own; or if he plants in his own and he engrafts into his own, with a public road or a private road intervening. It is, therefore, written (Shemoth 23:19) "the first-fruits or your soil" — All of the growths must be from your soil. For the same reason tenant-farmers, renters, holders of confiscated land, and robbers (of land) do not bring first-fruits.