Scottish Aggregates Tax: proposed approaches to cross-border taxation
This consultation seeks views on how to approach cross-border taxation for Scottish Aggregates Tax (SAT). This will enable the Scottish Government to gain feedback to inform policy development in advance of the planned introduction date of SAT on 1 April 2026.
Closed
This consultation closed 18 August 2025.
View this consultation on consult.gov.scot, including responses once published.
Consultation analysis
Glossary
Direct supply:
Where aggregate is supplied from a rUK quarry to a Scottish based customer. There are only two parties involved in the transaction, the supplier and the customer. The aggregate may be transported by the quarry operator to the customer; or the customer may collect the aggregate directly from the quarry.
Collections:
This is a type of direct supply where a customer based in Scotland collects aggregate from a rUK quarry, for use in Scotland. For example, where a Scottish based construction firm either sends their own haulage vehicle or hires a haulage firm to collect aggregate from a rUK based supplier for use in Scotland.
Indirect supply:
Cross-border scenarios that are not direct supplies. These scenarios will include more than two links in the supply chain. For example, this includes where aggregate is moved into Scotland from a rUK based middleman who has sourced the aggregate from a rUK quarry.
Middlemen:
This is a type of indirect supply where a business acts as a middleman between the aggregate producer and end user of aggregate. For example, a builders’ merchant who has sourced aggregate from a rUK quarry and supplied that aggregate to a Scottish customer.
Over-the-counter sales:
Where a rUK based middleman, such as a builders’ merchant, supplies aggregate to a Scottish based customer from their own stock of aggregates.
Producer-based delivery:
Where aggregate is supplied from a rUK middleman to a Scottish customer but sourced from a rUK quarry who also delivers it to the Scottish customer on the middleman’s behalf.
Tax credit:
Tax credits can be claimed in certain circumstances for SAT or UKAL in order to reduce a tax charge. To avoid double taxation, if required circumstances are met, a taxpayer can claim a tax credit (from Revenue Scotland or HMRC as appropriate) for aggregate which is moved across the border.
Contact
Email: Cara.Woods@gov.scot