I've heard various explanations for this over the years, including the suggestion that it was a "thank you" to private yacht owners after Dunkirk. A nice story, but it sems unlikely, somehow.
I suspect that the truth is more prosaic - i.e. that in the old days, (by which I mean pre WW2) private yachtsmen would fill up their boats at the same pumps as commercial sailors - fishermen and the like, who were exempted from tax because, like farmers, it related to their livelihood - and the amount of tax foregone in consequence was so trivial that the government didn't bother about it. In those days, people also had bizarre things like paraffin-powered engines in boats (which I assume was also untaxed) but by and large, didn't have petrol engines and, if they did, brought it from a garage in cans, paid tax and cursed inwardly.
Fast forward to today (or recently, anyway) and we have a situation, which has grown over the years without ever being formalised, whereby lots of people put large quantities of tax free diesel in their boats and the existence of the EU means that this state of affairs needs to be categorised. Hence "special exemptions" for leisure boaters, requiring "regular review".
Logically, it doesn't make sense and I suspect that it will go one day (although I think I'm right in saying that the UK govt. has just successfully negotiated an extension to the exemption?). A pity; I don't have a strong axe to grind about this one way or the other, as my pride and joy runs on petrol, and I cough up with a weary smile on my face. However, I aspire to own a boat big enough to need diesels one day - which will undoubtedly mark the day on which the exemption will be rescinded. 
Je suis Marxiste - tendance Groucho
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Why is boaty diesel tax free?
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