Breaking New Ground? Developing a Scottish tax to replace the UK Aggregates Levy Consultation Analysis Report

Report on the responses to the Scottish Government consultation regarding the structure and operation of a Scottish Aggregates Tax

2. Overview of Consultation and Engagement

The Scottish Government’s Framework for Tax sets out a commitment to tax policy making that is rooted in a defined set of principles and objectives, rigorously appraised and developed through an established policy cycle, which puts proactive engagement at the heart of tax policy making.

Consistent with the Framework for Tax, the Scottish Government has sought throughout its approach to consultation and engagement to ensure that proposals for SAT take account of the views of stakeholders, are well-designed, reflect the Scottish context and take advantage of the opportunities offered by devolution, including in terms of tax administration.

More specifically, the Scottish Government has considered the responses to a formal consultation held in late 2022, the points raised in engagement with various stakeholders, available evidence and research and the views of members of an advisory group convened in March 2023. Commentary on these elements is provided below.

Consultation Document

In September 2022, the Scottish Government published a consultation document to inform the development of a future Bill. The consultation ran for 12 weeks.

The consultation included a range of open and closed questions on several issues, including on rationale and context, scope, exemptions and reliefs, tax rates and administration. Views were also sought to inform the active and ongoing consideration of the various impact assessments for the Bill. For all closed questions, respondents had an opportunity to offer comments to support their views.

24 responses were submitted to the consultation. They came from a broad range of respondents, made up of 21 organisations and three individuals. For the purposes of the analysis, respondents have been broadly categorised as follows:

Type of Organisation Number of Responses
Primary Aggregates Industry 4
Waste and Resource Management 5
Other Industry 4
Environmental 3
Tax, Accountancy or Legal 3
Local Authority 2
Individuals 3

The consultation responses were analysed by officials from the Scottish Government and Revenue Scotland. Key findings from the analysis are presented in chapters 3, 4 and 5 of this document.

For Chapter 3, the analysis groups the relevant questions from each chapter of the consultation together, summarising and analysing the responses received in turn. Relevant discussion at the Scottish Government’s advisory group is highlighted, followed by a summary of the Scottish Government’s response and commentary on the relevant elements of the Aggregates Tax and Devolved Taxes Administration (Scotland) Bill, as introduced to the Scottish Parliament.

For Chapters 4 and 5, the analysis again groups together the questions from each chapter of the consultation. However, a single summary of any advisory group discussion and commentary on the Bill is then provided at the end of each section.

A list of respondents is also set out in Annex B. Where permission has been given, responses have been published in full on the Scottish Government’s consultation webpage at

Other Engagement

Scottish Government and Revenue Scotland officials have also met with a range of stakeholders to discuss their views.

Meetings took place with industry representative bodies and with the Convention of Scottish Local Authorities (COSLA), given councils’ use of aggregate for purposes including housebuilding, infrastructure works and roads maintenance.

Officials engaged with the Scottish Environment Protection Agency (SEPA) to learn from their experience of supporting Revenue Scotland’s Scottish Landfill Tax compliance work and with Transport Scotland, given the relevance of aggregates for road construction and maintenance. Meetings have been held with UK Government officials from HMRC and HM Treasury to support an understanding of the operational and policy contexts of UKAL, and consideration of how this could inform the design of the devolved tax.

During and after the initial consultation period, Scottish Government and Revenue Scotland officials visited several aggregate production sites operated by both primary and recycled aggregates producers. Officials also visited the British Geological Survey to learn more about Scotland’s complex geology and how its resources of rock, gravel and sand have been produced and used over time. The Scottish Government would like to thank all those who facilitated and hosted visits.

Advisory Group

In early 2023, taking consultation feedback and stakeholder views into account, the Scottish Government concluded that further work was needed to ensure that decisions on policy positions for SAT were based on optimal evidence. An advisory group was convened to help inform this process.

Further information on the advisory group, including on its membership, is available in Annex A. Where appropriate, the issues raised in discussion at the group are referenced in the consultation analysis commentary.

Other Considerations

In addition to the above, the Scottish Government has taken a range of relevant sources of evidence into account. These include the report of the UK Government's 2020 review of UKAL, relevant UK statistics and Scottish Government commissioned research into options for a devolved tax.



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