Relief for Land Acquisitions by Visiting Forces and Military Headquarters in UK

SDLT relief for land bought for visiting forces and NATO headquarters

This is a limited Stamp Duty Land Tax relief for land acquired for certain visiting armed forces in the UK and certain NATO-related military headquarters. It only applies where the country or headquarters has been formally designated by Order in Council, the land is acquired for specific military purposes, and the relief is properly claimed through the SDLT return.

• The relief is not a general exemption for foreign service personnel or defence-related bodies.
• It can apply to land acquired for designated visiting forces invited to the UK by His Majesty’s Government, or for designated international military headquarters under the North Atlantic Treaty.
• The acquisition must be for a qualifying purpose, such as building or enlarging barracks or camps, supporting training in the UK, or promoting the health or efficiency of the force.
• Individual members of a visiting force do not qualify if they buy property in a private capacity, such as a home for personal use.
• A key legal requirement is formal designation by Order in Council of the relevant country or headquarters.
• Even if the transaction is exempt, the relief must still be claimed on the SDLT return, or by amending the return, using HMRC relief code 28.

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SDLT relief for land acquired for visiting forces and NATO military headquarters

This page explains a narrow Stamp Duty Land Tax relief for certain land transactions connected with visiting armed forces in the UK and certain international military headquarters. The relief is not a general exemption for service personnel. It applies only in specific cases where land is acquired for defined military purposes and where the country or headquarters has been formally designated.

What this rule is about

The rule deals with land bought or otherwise acquired for use by foreign armed forces that are in the UK at the invitation of His Majesty’s Government, and for certain international military headquarters established under the North Atlantic Treaty.

The policy behind it is limited. Where land is being acquired for recognised visiting forces or qualifying headquarters, and the acquisition is for particular operational or support purposes, the transaction can be exempt from SDLT.

This is a specialist relief. Most land transactions involving overseas personnel or defence-related bodies will not fall within it unless the statutory conditions are met.

What the official source says

The HMRC manual refers to relief under FA 1960, section 74A. It says the relief applies to certain acquisitions of land for use by:

• visiting forces of designated countries that are present in the UK at the invitation of HM Government, or
• designated international military headquarters established under the North Atlantic Treaty.

For the relief to apply, the relevant country or headquarters must be designated by Order in Council for this purpose.

A land transaction is exempt from charge if it is entered into with a view to:

• building or enlarging barracks or camps for the visiting force of a designated country,
• facilitating the training in the UK of such a force, or
• promoting the health or efficiency of such a force.

The manual also says that, for this purpose, a designated international military headquarters is treated as if:

• it were a visiting force of a designated country, and
• the members of that force were the persons serving at or attached to the headquarters who are members of the armed forces of a designated country.

The relief does not apply to individual members of a visiting force who acquire land or property in a personal capacity.

HMRC also states that the relief must be claimed in a land transaction return, or by amending that return, using code 28 for other reliefs.

What this means in practice

There are several separate conditions, and each matters.

First, the transaction must involve a qualifying force or headquarters. It is not enough that the buyer is connected with defence activity or with a foreign military. The country or headquarters must be formally designated by Order in Council.

Second, the acquisition must be for one of the listed purposes. The wording is purpose-based. That means you need to look at why the land transaction is being entered into. The manual identifies three broad categories:

• accommodation and infrastructure for the force, such as barracks or camps,
• training in the UK, or
• health or efficiency of the force.

Third, the relief is aimed at land acquired for the force or headquarters, not at private purchases by individuals. If a member of a visiting force buys a house or flat for personal use, that is outside this relief even if they are stationed in the UK.

In practical terms, a conveyancer or tax adviser would want to confirm:

• who the purchaser is, or on whose behalf the land is being acquired,
• whether the relevant country or headquarters has been designated, and
• whether the transaction is genuinely entered into for one of the statutory purposes.

If those points are satisfied, the transaction may be exempt from SDLT, but the relief still needs to be claimed through the SDLT return process.

How to analyse it

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

1. Is this an SDLT land transaction in the usual sense?

   The relief sits within the SDLT framework. You first identify the transaction in the normal way.

2. Is the transaction connected with a visiting force of a designated country, or with a designated international military headquarters?

   The designation point is essential. The manual makes clear that the country or headquarters must be designated by Order in Council.

3. Is the force in the UK at the invitation of HM Government?

   For visiting forces, the official material ties the relief to forces present in the UK on that basis.

4. What is the purpose of the acquisition?

   You should test the transaction against the listed purposes: building or enlarging barracks or camps, facilitating training in the UK, or promoting health or efficiency. The closer the facts are to those purposes, the stronger the case for relief.

5. Is the acquisition being made by or for the force or headquarters, rather than by an individual in a private capacity?

   This is a clear boundary in the manual. Personal acquisitions by individual service members do not qualify.

6. Has the claim been made correctly?

   HMRC says the relief must be claimed in the land transaction return or by amendment, using the specified relief code.

Example

Illustration: a formally designated NATO-related military headquarters acquires land in the UK to expand accommodation and operational facilities used by armed forces personnel serving at that headquarters. If the headquarters is designated by Order in Council and the acquisition is entered into with a view to building or enlarging barracks or camps, the transaction may fall within this relief.

By contrast, if an individual officer attached to that headquarters buys a house nearby for their family, that purchase is in a personal capacity and the manual says this relief does not extend to it.

Why this can be difficult in practice

The main difficulty is usually not the broad idea of the relief, but whether the facts fit the statutory purpose closely enough.

For example, some acquisitions may obviously relate to barracks or training. Others may be less straightforward, especially where land is being acquired for mixed uses or for support functions that are said to promote the health or efficiency of the force. The manual gives the statutory categories but does not spell out every factual boundary.

Another practical issue is status. A defence connection is not enough by itself. The designation by Order in Council is a specific legal requirement, and the transaction must relate to the designated force or headquarters in the required way.

There is also an administrative point. Even where the transaction is exempt, HMRC says the relief must be claimed through the SDLT return process. A missed claim may need to be corrected by amendment if that is still possible.

Key takeaways

• This is a narrow SDLT relief for land acquired for certain designated visiting forces and designated international military headquarters.
• The country or headquarters must be designated by Order in Council, and the acquisition must be for one of the specified military purposes.
• The relief does not apply to private property purchases by individual members of a visiting force, and it must be claimed in the SDLT return.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: Relief for Land Acquisitions by Visiting Forces and Military Headquarters in UK

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