Scottish Aggregates Tax - administration regulations: business and regulatory impact assessment

Section 2: Consultation

Development phase

Prior to public consultation on the proposed introduction of SAT regulations and related changes to wider legislation, the Scottish Government engaged an SAT expert advisory group on the proposed SAT administration regulations.

Established in January 2023, the advisory group has provided expertise informing the development of the Aggregates Tax and Devolved Taxes Administration (Scotland) Act 2024 (“the 2024 Act”) and continues to provide expertise on preparation for the implementation of SAT.

Advisory group members are drawn from a range of backgrounds, including industry representative bodies for both primary and recycled aggregate producers, aggregates consumers (including key public sector bodies), corporate stakeholders with an interest, and environmental organisations.

In particular, the SAT advisory group includes representatives from trade bodies representing the majorities of companies producing primary and recycled aggregate in Scotland. These are:

• The British Aggregates Association, a trade body for independent small and medium size quarry operators.
• The Mineral Products Association, a trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar, and industrial sand industries.
• Resource Management Association Scotland, a trade body for micro, small and medium sized resource management companies.

Revenue Scotland engagement to date has focussed on the development of the registration process and the tax return. Input has been received from representatives of the British Aggregates Association, Mineral Products Association, Chartered Institute of Taxation, Institute for Chartered Accountants of Scotland, the British Geological Survey and individual businesses. This engagement has helped Revenue Scotland develop the registration process and tax return and further engagement is planned with future SAT taxpayers in order to ensure that these processes are well understood prior to SAT being introduced on 1 April 2026.

Within Government

The Tax Division within the Scottish Government has a network of stakeholder organisations with an interest in tax policy. Government organisations and departments with a policy interest in proposals are contacted in respect of these proposals and consultation documents are made available to these bodies.

This includes direct contact and discussion with the following during the development phase of the consultation:

• Revenue Scotland.
• Civil Law and Legal System Division.

Business consultation

As these regulations are most relevant to businesses who will be SAT taxpayers, business engagement is a crucial component of policy development.

Businesses, who will be SAT taxpayers, were represented on the SAT advisory group through the development phase of the consultation and further engagement with businesses took place once the consultation was launched to enable a full discussion on the technical and financial implications of the proposed secondary legislation on businesses.

Public consultation

This Impact Assessment formed part of a package issued for public consultation. This consultation sought comments on draft regulations to inform the development of the final regulations to be introduced to the Scottish Parliament.

Prior to the consultation, the Scottish Government also engaged with an SAT expert advisory group on the proposed SAT administration regulations.

Notification of the consultation was issued to a list of organisations previously identified as having an interest in SAT.

The consultation ran for an 8-week period between 24 January 2025 and 21 March 2025.

Three responses to the consultation were received from stakeholder groups. Two of the three respondents to the formal public consultation requested that their responses not be published.

Two responses were also received from the SAT advisory group members prior to the launch of the consultation. For the purposes of the analysis, the two responses from SAT advisory group members were included, and respondents were broadly categorised (see Table 1).

Respondents provided a range of comments on each of the draft provisions. While there is evidence of consensus in some areas, a number of unique concerns and proposed amendments were highlighted.

Where permission has been given, responses have been published in full on the Scottish Government’s consultation hub, Citizen Space - Published responses for Scottish Aggregates Tax - proposed administration regulations.

The consultation responses were analysed by officials from the Scottish Government and Revenue Scotland. This also included engagement with stakeholders separately on points raised as part of the consultation.

The material and views gathered through the consultation activities have informed the development of SAT policy in advance of 1 April 2026, which is the date on which SAT becomes operational. Key findings from the analysis are presented in the consultation analysis report.