Scottish Aggregates Tax - proposed administration regulations

We sought views on the proposed administration regulations for the Scottish Aggregates Tax (SAT). Views were also sought on a range of issues to inform relevant impact assessments and ensure that these are fully considered. The consultation opened on 24 January and closed on 21 March 2025. 

Five responses to the consultation were received from various stakeholder groups. Two of those responses were received from the SAT expert advisory group members prior to the launch of the consultation. For the purposes of the analysis, the two responses from SAT advisory group members have been included, and respondents have been broadly categorised. One response was received from a primary aggregates industry body, one response was received from a waste and resource management body, and three responses were received from tax/accountancy/legal bodies. 

Most respondents agreed with the majority of the provisions in the draft administration regulations and impact assessments. However, it was noted that there will be an additional administrative burden on taxpayers due to the level of information being requested in the aggregates invoice and tax return. A key theme in the responses was that the definition of an aggregates invoice (as stipulated in the draft secondary legislation) would cause problems for the primary aggregates industry, and that this should be amended. 

Respondents also sought further clarity on the following provisions: 

• Penalties for failure to use a weighbridge/specified method  

• Group registration 

• 30-day tax return period  

• Time-limit for claims 

Stakeholder feedback on the partial Business and Regulatory Impact Assessment (BRIA) proposed:  

• Greater reference to the research being undertaken via ClimateXChange, a centre for expertise on climate change, to better understand the evidence base on the role of recycled aggregates. 

• Further detail on the compliance costs to affected businesses.  

• An update on the assessment of cross-border complexities. 

• Information on the number of visits undertaken and the methodology used to select which operators were approached / visited. 

• Post-implementation review: further information is needed on what intervals the reviews will take place, how these will be carried out, and the level of detail to assess effectiveness of SAT. 

The material and views gathered through the consultation activities have informed the development of SAT policy in advance of the proposed introduction date of 1 April 2026. 

The Scottish Government has carefully considered the responses to the consultation and amendments have been made to regulation 2 on the definition of an aggregates invoice. Other amendments were made to correct minor spelling mistakes and referencing errors within the regulations. 

Further clarity has been provided in the consultation analysis report to answer stakeholder queries on a number of issues highlighted. 

The Business and Regulatory Impact Assessment has also been revised to include further information, as highlighted by respondents, and to answer queries raised.