Stamp duty relief for lighthouse authority land deals
Lighthouse authority SDLT relief
A land deal can be exempt from SDLT where it is made by, or under the direction of, a named general lighthouse authority for services funded through the General Lighthouse Fund.
- The rule covers only three named authorities.
- The deal’s purpose and funding link matter.
- HMRC says to use relief code 28 in the SDLT return.
Scroll down for the full analysis.
Read the original guidance here:
Stamp duty relief for lighthouse authority land deals
A qualifying land deal by a lighthouse authority can be exempt from stamp duty land tax (SDLT). This is a narrow rule. A named authority must enter into or direct the deal, and the deal must support services that the General Lighthouse Fund pays for.
What this rule is about
Lighthouses and related navigation services require land for buildings, equipment and access, and Parliament has provided a limited SDLT exemption for certain deals connected with those services. It is limited.
This is not relief for every organisation connected with a lighthouse. The body’s identity, the reason for the deal and its funding all matter.
What the official source says
Section 221 of the Merchant Shipping Act 1995 exempts a qualifying land deal from SDLT when the statutory conditions link the transaction to qualifying lighthouse services. HMRC’s manual explains that the exemption applies when a general lighthouse authority enters into the deal itself, or directs another party to enter it. That is the test.
- Trinity House is one of the named authorities.
- The rule names the Commissioners of Northern Lighthouses.
- The rule names the Commissioners of Irish Lights.
- The deal must support services that the General Lighthouse Fund funds.
HMRC’s manual also tells claimants to claim the relief in the SDLT return, or in an amendment to that return. It says to enter code 28, Other reliefs, at question 9.
What this means in practice
When the relevant authority enters or directs the deal, the deal supports a service that the General Lighthouse Fund funds, and all legal conditions are satisfied, SDLT is not charged on the deal. That is the result. The point concerns who acts and why, not the type or value of the land.
- Check whether one of the three named bodies entered into the deal.
- If another body signed, check whether it acted under a named authority’s direction.
- Keep records linking the deal to services funded by the General Lighthouse Fund.
HMRC’s manual is guidance rather than law. Still, it explains how HMRC expects the exemption to appear on its return.
How to analyse it
Begin with the facts behind the deal. A label such as “lighthouse project” does not determine the answer.
- Identify the party that entered into the land deal.
- Check whether that party is one of the three named authorities.
- If not, establish whether it acted under one authority’s direction.
- Identify the service the land will support.
- Confirm whether the General Lighthouse Fund funds that service.
- Where an SDLT return is needed, record the claim as HMRC’s manual directs.
- If a return has already been filed, check whether it can still be amended.
Example
Suppose Trinity House takes a lease of land for equipment used in a navigation service. If the General Lighthouse Fund funds that navigation service and the lease meets the other legal conditions, the lease can fall within the exemption. It may qualify. By contrast, a lease for an unrelated activity would not qualify merely because Trinity House was involved.
Why this can be difficult in practice
The funding and purpose link will often require the closest scrutiny, particularly where a project has several aims, draws money from several sources, and records its connections imperfectly. The papers should show the connection clearly.
- A contractor working near a lighthouse is not automatically a general lighthouse authority.
- Land used partly for a qualifying service may need closer analysis.
- Using code 28 does not replace the need to meet the statutory conditions.
Key takeaways
- The exemption is for a small group of named lighthouse bodies.
- The land deal must support services funded through the General Lighthouse Fund.
- HMRC says to claim the relief with code 28 in question 9.
Technical analysis
For advisers, and for anyone who wants to check the law behind this page. You do not need this section to understand the guidance above.
Legislation
- an Act of 1995 we do not have an identifier for section 221 — exemption for qualifying lighthouse authority land deals (no link: an Act of 1995 we do not have an identifier for)
- FA 2003 section 76 — duty to file a land transaction return
- FA 2003 Schedule 10 para 6 — amending a land transaction return
Official guidance
The pages below are HMRC’s guidance. Guidance is not law. It sets out how HMRC reads the legislation, and it is not binding on you, on a tribunal or on a court. Where guidance and the legislation differ, the legislation wins. HMRC can also change or withdraw guidance, and it may not cover your facts.
Where this is not settled
- The supplied material does not confirm the current text of Merchant Shipping Act 1995 s.221 after the date of the source materials.
- The supplied material does not verify whether HMRC’s online return questions and relief codes remain unchanged.
Evidence you would need
This kind of case is decided on the facts of the individual property. These are the records that usually settle it, and the ones an adviser would ask you for.
- The authority entering into, or directing, the land deal
- Documents showing why the land was bought, leased or otherwise obtained
- Evidence that the relevant services are funded through the General Lighthouse Fund
- The SDLT return, any amendment and supporting transaction documents
Explore this with an AI
Readers often want to test their own situation. Copy the prompt below into ChatGPT, Claude or Gemini. It hands the model the actual legislation for this page rather than letting it answer from memory, and tells it to be explicit about what is uncertain. What comes back is information, not advice – check it against the links above.
I am researching UK Stamp Duty Land Tax (SDLT), which applies in England and Northern Ireland. MY QUESTION Stamp duty relief for lighthouse authority land deals [Replace this with your own situation: what you are buying, the price, the dates, who the buyer is, and what you plan to do with the property.] THE LAW THIS TURNS ON - an Act of 1995 we do not have an identifier for section 221 - exemption for qualifying lighthouse authority land deals - FA 2003 section 76 - duty to file a land transaction return https://www.legislation.gov.uk/ukpga/2003/14/section/76/2025-11-17 - FA 2003 Schedule 10 para 6 - amending a land transaction return https://www.legislation.gov.uk/ukpga/2003/14/schedule/10/paragraph/6/2025-11-17 HMRC's guidance page on this topic (guidance, not law): https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm29690 HOW I WANT YOU TO ANSWER 1. Work from the legislation above. Read it before answering. HMRC guidance is HMRC's view of the law, not the law, and does not bind a tribunal or a court. 2. Tell me what the rule actually requires, in plain English. 3. Tell me which facts decide the answer, and which facts would change it. 4. Tell me what evidence I would need to support the position. 5. Be explicit about anything unsettled or fact-sensitive. Do not guess. 6. Your training data has a cutoff and SDLT rates and reliefs change at fiscal events. Say so if you are not sure the law is current. POINTS ALREADY KNOWN TO BE UNCERTAIN ON THIS TOPIC - The supplied material does not confirm the current text of Merchant Shipping Act 1995 s.221 after the date of the source materials. - The supplied material does not verify whether HMRC's online return questions and relief codes remain unchanged. Do not give me a conclusion you cannot support from the provisions above.
Legislation links show Finance Act 2003 as it stood on 2025-11-17. The law may have changed since, and the rules that apply are those in force on the date of your transaction. The official guidance this page is based on is here.
This page was last updated on 1 September 2026
Useful article? You may find it helpful to read the original guidance here: Stamp duty relief for lighthouse authority land deals
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