Scottish Aggregates Tax: Options for approaching cross-border taxation – Consultation Analysis

1. Introduction

1.1 This report provides an analysis of responses to the Scottish Government consultation ‘Scottish Aggregates Tax: Options for approaching cross-border taxation’^[1] (hereafter referred to as “the consultation”). In addition, it sets out the Scottish Government’s response to the consultation and a summary of next steps.

1.2 Views were invited as part of an eight-week consultation period between 23 June 2025 and 18 August 2025. The consultation sought views on how to approach cross-border taxation to support the introduction and effective operation of Scottish Aggregates Tax (“SAT”).

1.3 This has enabled the Scottish Government to gain feedback from stakeholders to inform policy development in advance of the planned introduction date of SAT on 1 April 2026.

1.4 The consultation also sought views on a range of issues to inform relevant impact assessments.

1.5 Prior to the consultation, the Scottish Government, in collaboration with Revenue Scotland and HM Revenue and Customs (HMRC), engaged with industry representative bodies and wider stakeholders to help shape the options under consideration. The comments and feedback received during this engagement helped shape the consultation and are also summarised in this report. Where relevant, commentary is provided on decisions taken by the Scottish Government to develop SAT cross-border policy, following consultation and engagement.

1.6 Eight responses to the consultation were received. Two respondents requested that their submissions not be published (see Table 1). The Scottish Government would like to thank those who contributed to the pre-consultation engagement and respondents to the consultation.

Table 1: Responses received on the proposed approaches to SAT cross-border taxation

Respondent

Anonymous

Category

Individual

Respondent

Anonymous

Category

Individual

Respondent

Chartered Institute of Taxation (CIOT)

Category

Organisation

Respondent

Resource Management Association Scotland (RMAS)

Category

Organisation

Respondent

Travis Perkins PLC

Category

Organisation

Respondent

Mineral Products Association and Mineral Products Association Scotland

Category

Organisation

Respondent

The Builders Merchants’ Federation Ltd

Category

Organisation

Respondent

British Aggregates Association

Category

Organisation

1.7 Where permission was granted, responses have been published in full at www.consult.gov.scot.

1.8 The consultation responses were analysed by officials from the Scottish Government, in collaboration with officials from Revenue Scotland and HMRC. This also included engagement with stakeholders separately on specific points raised.

1.9 An executive summary is set out in Chapter 2. Key findings from the analysis are presented in Chapters 3 and 4. Chapter 5 outlines the next steps and the Scottish Government’s response to the consultation.