Lighthouse Land Transactions Exempt from Charge Under Merchant Shipping Act 1995

SDLT relief for general lighthouse authorities

A limited SDLT exemption can apply to land transactions involving certain UK general lighthouse authorities. To qualify, the transaction must be entered into by, or under the direction of, one of the named authorities and must be for services funded through the General Lighthouse Fund. Even if the exemption applies, it still needs to be claimed correctly in the SDLT return.

• This relief only applies to Trinity House, the Commissioners of Northern Lighthouses, and the Commissioners of Irish Lights.
• The transaction must be for carrying on services funded through the General Lighthouse Fund.
• The wording “by or under the direction of” may cover some transactions not entered into directly by the authority, but the facts and documents will be important.
• This is a specialist exemption and does not apply generally to maritime, port, or other public body transactions.
• The exemption must be claimed in the land transaction return, or by amendment, using code 28 under “Other reliefs”.

Scroll down for the full analysis.

SDLT relief for lighthouse authorities

This page explains a narrow Stamp Duty Land Tax relief for certain land transactions involving the UK’s general lighthouse authorities. If the conditions are met, the transaction is exempt from SDLT. The relief is not automatic in practice: it must be claimed in the land transaction return or by amending that return.

What this rule is about

The rule deals with land transactions entered into by specific statutory bodies involved in lighthouse and related navigational services. These bodies are referred to in the legislation as the general lighthouse authorities.

The point of the relief is to remove SDLT where a qualifying transaction is entered into for the purpose of carrying on services that are funded through the General Lighthouse Fund.

This is a specialist exemption. It is not a general relief for maritime activity, port operations, or public bodies more widely.

What the official source says

The official material states that, under section 221 of the Merchant Shipping Act 1995, a land transaction is exempt from charge if it is entered into by, or under the direction of, one of the following:

• Trinity House
• the Commissioners of Northern Lighthouses
• the Commissioners of Irish Lights

These are the general lighthouse authorities.

The transaction must also be for the purpose of carrying on services funded through the General Lighthouse Fund.

The source also makes clear that the relief must be claimed. The claim is made in the land transaction return, or in an amendment to that return, using code 28 for “Other reliefs” at question 9.

What this means in practice

There are two main conditions.

• The transaction must involve one of the named lighthouse authorities, either directly or under its direction.
• The purpose of the transaction must be to carry on services funded through the General Lighthouse Fund.

If both conditions are met, the transaction is exempt from SDLT.

In practical terms, this means a conveyancer or tax adviser should not stop at asking who the buyer is. They should also ask why the land transaction is being entered into and whether the relevant services are funded through the General Lighthouse Fund.

The wording “by or under the direction of” is potentially wider than transactions entered into directly by the authority itself. It suggests that a transaction may still qualify where another person or entity enters into it on the authority’s direction. But the source does not explain the limits of that phrase, so the facts and documentation would matter.

The relief is also procedural. Even where the exemption is available, the return still needs to reflect that relief is being claimed in the way specified by HMRC.

How to analyse it

A sensible way to approach this is to work through the following questions:

• Is the transaction a land transaction within the SDLT rules?
• Was it entered into by Trinity House, the Commissioners of Northern Lighthouses, or the Commissioners of Irish Lights?
• If not directly by one of those bodies, was it entered into under the direction of one of them?
• What is the purpose of the transaction?
• Is that purpose the carrying on of services funded through the General Lighthouse Fund?
• Has the relief been claimed in the land transaction return, or if necessary by amendment?
• Has the correct relief code been used in the return?

Evidence is likely to matter. In a straightforward case, the transaction documents and internal approval records may show both the authority involved and the operational purpose of the acquisition or other land transaction.

Example

Illustration: Trinity House acquires land needed for infrastructure used in carrying on navigational services that are funded through the General Lighthouse Fund. On the face of the source material, that transaction can fall within the exemption, provided the relief is properly claimed in the SDLT return.

By contrast, if a transaction involved a different public body, or was not for the purpose of carrying on services funded through the General Lighthouse Fund, this specific relief would not apply on the basis of the material provided.

Why this can be difficult in practice

The source is short and leaves some practical questions open.

• The phrase “under the direction of” may require careful factual analysis. The source does not define what level of control, instruction, or connection is enough.
• The purpose test may not always be simple where land is acquired for mixed uses, future development, or broader operational reasons.
• The source refers specifically to services funded through the General Lighthouse Fund. That funding link may need to be evidenced rather than assumed.
• The legislation creates an exemption from charge, but HMRC’s manual also says the relief must be claimed in the return. In practice, the filing position still needs to be handled correctly.

So the key issues are usually identity, direction, purpose, and evidence.

Key takeaways

• This is a narrow SDLT exemption for land transactions involving the general lighthouse authorities.
• The transaction must be by, or under the direction of, one of the named authorities and for services funded through the General Lighthouse Fund.
• The exemption should still be claimed in the SDLT return, using code 28 under “Other reliefs”.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: Lighthouse Land Transactions Exempt from Charge Under Merchant Shipping Act 1995

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