Scottish Aggregates Tax - proposed approaches to cross-border taxation

The following section sets out the background to the consultation. 

The Scottish Government is seeking views on how to approach cross-border taxation for certain direct and indirect supplies of aggregate. The consultation will focus on two specific cross-border scenarios that we understand most usually occur.  These scenarios are:

• a collection scenario (where a customer in Scotland collects aggregate from a quarry in the rest of the UK for use in Scotland); and
• a middleman scenario (where a rest of UK quarry supplies to a rest of UK middleman who then supplies the aggregate to a Scottish customer).

However, the consultation additionally invites respondents to highlight other potential scenarios, which might arise and offer views on Scottish Aggregates Tax (SAT) and UK Aggregates Levy (UKAL) tax treatment. Feedback from this consultation will help inform policy development ahead of the planned introduction of SAT on 1 April 2026. 

The Scottish Government has proactively engaged with industry representative bodies and wider stakeholders ahead of this consultation, helping to shape the options under consideration. This engagement will continue to ensure that all relevant cross-border scenarios are reflected in the design of SAT.

This section also includes a glossary of terms used in the consultation paper.

Please see Chapter 1, pages 3 - 5 of the consultation paper.